Case Digest (G.R. No. 14128) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The United States v. Severino Valdes y Guilgan, G.R. No. 14128, decided December 10, 1918, the prosecuting attorney filed a complaint before the Court of First Instance of Manila charging Severino Valdes y Guilgan and Hugo Labarro y Bunaladi (alias Hugo Navarro y Bunadia) with arson. On April 28, between eight and nine o’clock in the morning, while M. D. Lewin was absent from his residence at No. 328 San Rafael Street, San Miguel, Mrs. Lewin was alerted by a neighbor, Mrs. Auckback, to smoke issuing from the lower floor. The servant Paulino Banal discovered a piece of jute sack and a rag soaked in kerosene oil burning between a post and a partition of the entresol. At that moment Valdes was cleaning in the entresol and Labarro was tending horses. Policemen, summoned by telephone, arrested both defendants the same morning. At the police station, Valdes made a signed confession (Exhibit C) admitting he set the fires—including prior attempts—in inducement of his co-defendant, wh Case Digest (G.R. No. 14128) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Complaint filed by the prosecuting attorney in the Court of First Instance charging Severino Valdes y Guilgan and Hugo Labarro y Bunaladi with arson.
- On May 20, 1918, judgment sentenced Severino Valdes to six years and one day of presidio mayor and half the costs; proceedings dismissed as to Hugo Labarro.
- Incident of April 28, 1918
- Between 8 and 9 o’clock A.M., Mrs. Auckback alerted Mrs. Lewin to smoke on the lower floor of the Lewin residence at No. 328 San Rafael Street, San Miguel.
- Servant Paulino Banal discovered a rag and a piece of jute sack, soaked in kerosene, burning between a post and an entresol partition.
- Severino Valdes was working in the entresol; Hugo Labarro was cleaning horses on the premises.
- Police, summoned by telephone, arrested both defendants the same morning.
- Confessions and Denials
- At the police station, Severino allegedly admitted setting the sack and rag ablaze and other prior fires, induced by Labarro at a peso per fire.
- In an affidavit at trial, Severino acknowledged making police statements but denied placing the incendiary materials, blaming servant Paulino.
- At arraignment, Severino claimed he only burned dry mango leaves—contrary to his police confession.
- Prior Attempts and Surveillance
- In the month preceding April 28, there were repeated attempts to burn the Lewin house.
- Policeman Antonio Garcia del Cid testified to seeing Valdes attempt entry into a warehouse containing previously burned straw.
Issues:
- Whether Severino Valdes committed the crime of frustrated arson of an inhabited house.
- Whether the police station confession was sufficiently corroborated to establish direct participation.
- Proper classification of the offense (frustrated versus consummated arson) and applicable penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)