Case Summary (G.R. No. L-46573)
Factual Background on the Crimes
At about 9:30 p.m. on November 19, 1999, Artemio Eba was attacked by five individuals including Sota and Gadjadli. Jocelyn Eba, Artemio’s daughter, testified that the accused, armed and conspiring, demanded food from Artemio who was fearful to open his door. They threatened to burn his house, which they tried to do using a torch made of coconut leaves, but Artemio extinguished it. The group nevertheless fired shots at the house, forcing Jocelyn to escape by jumping out a window. Artemio fled as well but was pursued and shot multiple times, resulting in his instantaneous death. The house was subsequently burned down completely.
Charges and Proceedings
Sota and Gadjadli were charged with:
- Murder under Article 248 of the Revised Penal Code (RPC), as amended by Republic Act (RA) No. 7659, incorporating qualifying circumstances including treachery, evident premeditation, and abuse of superior strength.
- Arson under Article 320 of the RPC, as amended by Presidential Decree No. 1613 (PD 1613), for setting fire to Artemio’s residential house causing total destruction of property valued at ₱30,000.00.
They pled not guilty and underwent a joint trial. The prosecution presented the victim’s children as primary witnesses, with Jocelyn’s testimony establishing the involvement of Sota and Gadjadli among the perpetrators.
Defense’s Position
The defense presented alibi and denial:
- Sota claimed he was at his parents’ house due to fever and chicken pox, supported by testimony that he consulted doctors locally and in Dipolog.
- Gadjadli asserted he was not involved and claimed Eusebio (Artemio’s son) had attempted to hire someone to kill Artemio. Gadjadli said he was at Artemio’s house earlier to warn him and witnessed others shooting Artemio but not himself or Sota engaging in the crime.
- Contradictory testimony on Sota’s whereabouts and Gadjadli’s alibi weakened their defenses.
Trial Court Decision
The Regional Trial Court found both accused guilty beyond reasonable doubt of murder and arson, sentencing each to reclusion perpetua for murder, civil indemnity of ₱50,000 for the victim’s death, and indemnity for damages resulting from arson. The court applied qualifying circumstances of treachery, evident premeditation, and the aggravating circumstance of superior strength for the murder conviction.
Court of Appeals Ruling
The Court of Appeals affirmed the RTC’s decision with modifications:
- The penalty for murder was set at reclusion perpetua (with the death penalty abolished after RA No. 9346).
- For arson, the penalty was an indeterminate prison term of six years and one day to twelve years of prision mayor minimum, and twenty years of reclusion temporal maximum.
- Monetary damages were increased, awarding ₱75,000 civil indemnity, ₱50,000 moral damages, and ₱30,000 exemplary and temperate damages with legal interest.
The CA emphasized the credibility of Jocelyn's testimony and affirmed that circumstantial evidence was sufficient to prove guilt beyond reasonable doubt.
Issues on Appeal
The sole issue raised was whether the courts failed to prove the guilt of the accused beyond reasonable doubt. The accused argued that the testimony was speculative and lacked clear identification of the actual perpetrators, and that their alibis were credible.
Supreme Court’s Findings on Credibility and Evidence
The Supreme Court upheld the lower courts' findings on the credibility of Jocelyn, noting that:
- The trial courts’ determinations on witness credibility are entitled to great deference as they have the opportunity to directly observe witness demeanor.
- Jocelyn was qualified to testify despite her young age under Rules of Court Rule 130, and her testimony was detailed, consistent, and unshaken under cross-examination.
- Circumstantial evidence, as allowed by jurisprudence, can be sufficient for conviction when it establishes guilt beyond reasonable doubt.
- The absence of evidence of ill motive or fabrication against Jocelyn further supported her credibility.
Analysis of Defenses
The Court found the defenses of alibi and denial weak:
- Sota’s claim of sickness was contradicted by witnesses, and testimony established his presence near the crime scene.
- Gadjadli’s timeline was implausible; he claimed to witness events hours before the actual incident and failed to reconcile inconsistencies in his statements.
- Denial without strong exculpatory evidence does not suffice to dismantle credible prosecution testimony.
Legal Principles on Murder and Circumstances
The Court applied the law on murder under Article 248 of the RPC, as amended by RA 7659, imposing reclusion perpetua (in lieu of death penalty per RA 9346). It confirmed that:
- Treachery exists when the attack is sudden and unexpected, affording the victim no chance to defend himself, which was clearly the case here.
- Evident premeditation requires deliberate reflection and planning before the killing.
- Abuse of superior strength is absorbed by the qualifying circumstance of treachery.
- The prosecution proved each element of murder beyond reasonable doubt: Artemio was killed, the accused caused his death, with qualifying circumstances, and it was not parricide or infanticide.
Legal Analysis on Arson and Syndicate Participation
Regarding arson, the Court ruled:
- The corpus delicti of arson was proven by the uncontroverted burning of the victim’s inhabited house.
- The accused acted as members of a syndicate (defined as a group of three or more persons), fulfilling the special aggravating circumstance under PD 1613.
- Even if the information did not specifically enumerate the syndicate aggravating circumstance, the clear allegation that f
Case Syllabus (G.R. No. L-46573)
Background and Procedural History
- Golem Sota and Amidal Gadjadli were charged with murder and arson before the Regional Trial Court (RTC) of Liloy, Zamboanga del Norte, in Criminal Case Nos. L-00355 and L-00356.
- The charges stem from incidents dated November 19, 1999, involving the unlawful killing of Artemio Eba and the arson of his residential house.
- The RTC found the accused guilty of murder and arson, sentencing both to reclusion perpetua and ordering indemnification to the heirs of the victim.
- On appeal, the Court of Appeals (CA) affirmed the RTC ruling but modified the penalties and damage awards.
- Sota and Gadjadli filed an appeal to the Supreme Court, claiming failure of the lower courts to prove guilt beyond reasonable doubt.
- The Supreme Court resolved to affirm the findings of the RTC and CA after thorough review of factual and legal issues.
Facts of the Case
- On the night of November 19, 1999, in Labason, Zamboanga del Norte, Sota, Gadjadli, and three other unidentified persons attacked Artemio Eba’s house.
- The group was armed and demanded food from Artemio; he agreed to comply but insisted on handing food through an opening in the wall.
- The group threatened to burn the house when Artemio refused to open the door; a torch made of coconut leaves was lit and the house set on fire.
- Artemio was shot and stabbed by the group, resulting in his instantaneous death.
- The house and belongings valued at Php30,000.00 were totally burned.
- The victim’s heirs suffered damages including indemnity for death and loss of earning capacity.
- The prosecution presented testimony mainly from Artemio’s daughter, Jocelyn, and son, Abelardo.
- The defense presented alibis and denials, including medical conditions that supposedly incapacitated Sota and conflicting claims about presence at the crime scene.
Prosecution’s Evidence and Arguments
- Jocelyn testified to seeing Sota and Gadjadli with three others demanding food and threatening to burn the house.
- Identification of Sota as the leader and Gadjadli carrying a pistol was based on clear observation due to bright moonlight.
- Jocelyn recounted that Gadjadli fired the first shot at Artemio and the group subsequently burned the house.
- Abelardo reported the incident to the authorities and submitted an affidavit.
- The prosecution argued that the presence of conspiracy, treachery, evident premeditation, and superior strength were established beyond reasonable doubt.
- The prosecution maintained that the accused had the requisite criminal intent and that the attack was deliberate and coordinated.
Defense’s Evidence and Arguments
- Sota claimed to have been incapacitated due to fever and chicken pox, staying at his parents' home adjacent to the crime scene.
- Gadjadli denied involvement, asserting he was neither present at the crime scene nor responsible, and implicated Eusebio (Artemio’s son) as a possible instigator.
- Defense witnesses contradicted one another regarding Sota’s presence and condition on the night of the incident.
- Gadjadli’s assertion of witnessing the shooting at 6:00 p.m. conflicted with the time of the incident reported by witnesses (9:30 p.m.).
- The defense primarily rested on alibi and denial, lacking strong evidence contradicting prosecution witnesses.
Trial Court’s Findings and Decision
- The RTC found Sota and Gadjadli guilty beyond reasonable doubt for murder and arson.
- The court ruled that the killings were characterized by qualifying circumstances of treachery and evident premeditation, and aggravating circumstance of superior strength.
- The court held the conspira