Case Digest (G.R. No. L-6273)
Case Digest (G.R. No. L-6273)
Facts:
People of the Philippines v. Jose Hidalgo y Resurreccion and Maura Gotengco y Soliman, G.R. No. L-6273, December 27, 1957, the Supreme Court En Banc, Endencia, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the defendants-appellants were spouses Jose Hidalgo y Resurreccion and Maura Gotengco y Soliman. Co-accused named in the informations included Florencio Camilo (alias Lin Siu), James Uy (alias James Kay), Aw Ming (alias Taba), and a John Doe.On the evening of October 8, 1950, a fire was discovered on the second floor of a two-wing building at the corner of Echague and Rizal Avenue, Manila. Firemen, led by Capt. Braulio Alonia, promptly extinguished the blaze and found on the Echague wing two broken glass jars, ten unbroken glass jars containing gasoline, toilet paper wicks arranged to connect the jars, and green tin covers; photographs and a sketch of the scene were introduced in evidence. The Echague wing housed the Republic Vocational School; the appellants occupied a room on the second floor in the Rizal Avenue wing. The fire’s origin was in a corridor about five to six meters from the appellants’ room.
The appellants owned the first floor and one-half of the second floor and had heavily insured the building: eight policies with a face value of P135,000 (six of which, totaling P70,000, were obtained about a month before the fire), and additional policies bringing the aggregate insured amount to P175,000, despite a reproduction cost estimated at about P89,524.59. The estimated loss from the fire was P5,255; no insurance claim was filed. Police investigation and the physical evidence suggested intentional ignition.
An information was filed on March 29, 1951, charging the appellants and others with arson; before trial the City Fiscal, over appellants’ opposition, excluded Florencio Camilo from the information and made him a state witness. At the Court of First Instance of Manila the spouses were convicted of arson on an inhabited building with aggravating circumstances of premeditation and nighttime, and were sentenced to reclusion perpetua with accessory penalties and ordered to pay joint and several indemnities to several insurers (specific sums set out in the judgment). Their co-accused James Uy and Aw Ming were acquitted by the trial court. The appellants appealed the conviction to the Supreme Court.
Issues:
- Was the prosecution’s exclusion of Florencio Camilo from the information so he could testify as a state witness proper under the Rules and applicable law?
- Was the corpus delicti of arson—i.e., that a fire occurred due to criminal agency—proven?
- Was the testimony of Florencio Camilo, an admitted accomplice, credible and sufficiently corroborated to support the conviction of the appellants, particularly in light of the acquittal of other co-accused?
- Did the other evidence (the checks issued by Maura, the heavy insurance, the physical evidence of gasoline jars and tissue wicks, and the gasoline analysis) sufficiently corroborate Camilo’s testimony to sustain conviction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)