G.R. No. 166547 - Tomawis vs. Tabao-Caudang

An Information was filed on June 14, 1989 charging Gaudencio Legaspi, Carlito de Leon, Bien de Leon, Cornelio "aka" Nelio Cabildo, and Filoteo de Leon with the crime of arson.
Gaudencio Legaspi died on February 5, 1987, prior to his arraignment, while the remaining appellants were subsequently arraigned and pleaded not guilty.
The Regional Trial Court of Nueva Ecija, Branch 35, found the appellants guilty beyond reasonable doubt for arson and sentenced them to suffer an indeterminate prison term (with a minimum of prision mayor and a maximum of reclusion temporal) and ordered them to pay damages to the private complainant’s heirs.
The Court of Appeals, in its decision dated May 21, 2007, modified the trial court’s decision by imposing reclusion perpetua and increasing the damages to temperate damages of ₱2,000 and exemplary damages of ₱20,000.
The instant appeal by the appellants was eventually denied by the Supreme Court, which affirmed the decision of the Court of Appeals.

On April 5, 1986, at around 8:30 p.m., the incident occurred at a tumana in Polillo, San Josef, Peñaranda, Nueva Ecija, where the hut owned by Rafael Mercado was located.
Aquilina Mercado Rint, her sister Leonisa Mercado, and their nephew Narciso Mercado Jr. were inside or near the house when they observed through a window that five men were approaching.
Recognizing the approaching men as Gaudencio Legaspi and the appellants, Aquilina and Leonisa quickly exited the hut and hid behind a pile of wood, while Junior was sent to secure assistance.
The witnesses observed the group surround the hut and deliberately set fire to the cogon roofing, which subsequently led to the complete burning of the structure.
Shortly after the incident, on April 6, 1986, Police Officer Lucio Mercado conducted an investigation, noting that significant remains of burning, including large pieces of wood still aflame, were evident.
Additional evidence included photographs taken of the scene and the testimonies of multiple witnesses that highlighted prior incidents of property damage allegedly committed by the appellants before the main event.

Eyewitness testimony by Aquilina and Leonisa Mercado was pivotal, as both positively identified the appellants as the perpetrators, detailing the sequence of events when the house was burned.
Testimonies described how Gaudencio Legaspi initiated the act by lighting a match and setting the cogon roofing on fire, with his co-accused following suit, thereby confirming the deliberate nature of the act.
The physical evidence at the scene—namely the charred remains of the structure and other burned materials—corroborated the testimony, satisfying the requirements for establishing corpus delicti.
Contradictory statements by the appellants were noted; for instance, Carlito de Leon alleged he was in Cavite at the time, while also later admitting involvement in related acts of destruction, thereby undermining their alibi.
Additional conflicting evidence was presented when another appellant, Nelio, testified that there were no structures on the premises and attributed the burnt material to natural causes, a claim that was not substantiated by the physical evidence and eye-witness accounts.

Prior to the arson, the appellants had been involved in disputes with Rafael Mercado, including alleged physical attacks, threats, and previous cases filed for Malicious Mischief, Forcible Entry, and Serious Physical Injuries.
There was also an ongoing contention over the control and rights to the tumana, with Carlito de Leon asserting family claims, including an application for a patent over the property following Gaudencio’s death.
The damage assessment by Aquilina and Leonisa included not only the destruction of the hut valued at ₱3,000 but also the loss of other household contents and personal property, contributing to the argument for awarding both temperate and exemplary damages.

Whether the prosecution proved beyond reasonable doubt the essential elements of the offense of arson, particularly the intentional burning of an inhabited dwelling.
Whether the physical evidence (burned remains and cogon roofing) and eyewitness testimonies satisfactorily established the corpus delicti of the crime.

Whether the testimony of eyewitnesses Aquilina and Leonisa Mercado, despite alleged inconsistencies, was sufficiently credible to support the conviction.
Whether the trial court properly evaluated the demeanor and reliability of the eyewitnesses versus the self-serving alibis provided by the appellants.

Whether the imposition of the maximum penalty of reclusion perpetua was warranted under Section 3 and Section 4 of Presidential Decree No. 1613, given the syndicate nature of the crime.
Whether the award of temperate damages and exemplary damages was in accordance with the evidence of the losses incurred by the private complainant.

Whether the crime, being committed by a syndicate (a group of three or more persons), constituted a special aggravating circumstance justifying the heightened penalty.