G.R. No. 203121 - People vs. Sota

Golem Sota and Amidal Gadjadli were charged before the Regional Trial Court (RTC), Branch 28, Liloy, Zamboanga del Norte, for:

Murder (Criminal Case No. L-00355) — Killing Artemio Eba on the evening of November 19, 1999, in Labason, Zamboanga del Norte, by means of treachery and evident premeditation, inflicting multiple gunshot and stab wounds resulting in instantaneous death.
Arson (Criminal Case No. L-00356) — Setting fire to Artemio Eba’s residential house the same evening, causing total destruction of the property and belongings valued at P30,000.00.

The information alleged conspiracy, confederation, and mutual assistance between Sota, Gadjadli, and three other persons.
The estimated damages suffered by the heirs of the victim included civil indemnity and loss of earning capacity for the murder case, and value of property destroyed for the arson case.

Witness Jocelyn Eba, daughter of the victim, testified that at about 9:30 p.m. on November 19, 1999, she observed Sota, Gadjadli (carrying a pistol), and three others outside their house demanding food from her father, Artemio.
Artemio refused to open the door fearing harm, offering to hand food through an opening in the wall.
The group threatened to burn the house if Artemio did not comply. A torch made of coconut leaves was lit and set to the house, which Artemio was able to extinguish.
The group then fired shots at the house; Gadjadli fired the first shot. Jocelyn escaped through a window and observed the house burning and Artemio being shot as he ran down the house.
The following day, Artemio’s body was found with stab and gunshot wounds.

Sota claimed he was at his parents’ house due to fever and chicken pox and did not see Gadjadli or have any involvement in the crimes.
Gadjadli testified that Eusebio Eba (Artemio’s son) asked him for someone to kill Artemio for P30,000, which he refused. He claimed to have witnessed Eusebio, Solaydi, and a masked man shooting Artemio at around 6:00 p.m. on the incident day and shouted a warning to Artemio and his daughter to run.
Saaban, a Barangay Kagawad, corroborated Sota’s illness and treatment around the incident date, asserting Sota was incapacitated.
Janjali testified seeing Sota go to Dipolog for medical treatment and only return days after the incident.
Both accused denied involvement in the burning or killing.

RTC found Sota and Gadjadli guilty beyond reasonable doubt of murder and arson.
The murder was qualified by treachery and evident premeditation, with superior strength as an aggravating circumstance (later held absorbed by treachery).
The arson was committed with hatred or resentment and by conspiracy with others.
Sentences: Reclusion perpetua for murder; indeterminate prison term for arson.
Monetary awards for civil indemnity and damages for both crimes were ordered.

The CA affirmed the RTC's guilty verdict but modified the penalties and damages.
Imposed reclusion perpetua for murder; indeterminate prison term for arson with specified minimum and maximum periods.
Increased damages considerably, including civil indemnity, moral, exemplary, and temperate damages with interest.

Whether the prosecution proved the guilt of the accused-appellants, Golem Sota and Amidal Gadjadli, beyond reasonable doubt for the crimes of murder and arson.