Title
People vs. Miranda
Case
G.R. No. 1296
Decision Date
Oct 26, 1903
Banca inspector Gregorio Miranda convicted of arson, with circumstantial evidence proving guilt; subsidiary imprisonment ordered for indemnification.

Case Summary (G.R. No. 1296)

Charges and Initial Ruling

Gregorio Miranda was charged with the offense of burning a banca that belonged to Luis Yanco. The Court of First Instance convicted him of this offense and sentenced him to six months and one day of prision correccional, ordered him to pay costs related to the proceedings, and directed him to provide indemnification of 1,000 pesos to Yanco as compensation for the destruction of the banca. The court also stipulated that should Miranda be unable to meet these financial obligations, he could face subsidiary punishment.

Circumstantial Evidence

The conviction relied entirely on circumstantial evidence. The defense contended that the evidence presented did not sufficiently prove Miranda's guilt beyond a reasonable doubt. The key facts presented included that on the night of the fire, the banca was unattended, and significant evidence pointed to the fire being of incendiary origin, including the presence of dried cane branches and petroleum odor nearby. Furthermore, it was emphasized that there was no apparent accidental cause for the fire.

Conflict of Interest and Threats

Miranda held a position as an inspector for bancas and had previously enforced local ordinances against those operating Yanco's banca, indicating a potential conflict of interest. Witness testimony revealed that Miranda exhibited hostility toward the operations of Yanco’s banca, suggesting that he may have been motivated by jealousy, particularly given that the banca was larger and more capable than his own. Notably, on the day of the fire, Miranda threatened the pilot of Yanco's banca, indicating dire consequences if his instructions were not followed.

Defendant's Testimony and Inconsistencies

During the trial, Miranda's testimony was marked by contradictions. Initially, he claimed ignorance of whether the banca had burned, and later admitted knowledge of the incident, albeit under confusing circumstances. He failed to investigate or report the fire promptly, which would have been expected of him in his role as inspector. His whereabouts during the fire were questionable, as he claimed to have been involved in a wake and ignored the incident despite living in close proximity and having surveillance duties over the bancas.

Conclusion and Modification of Sentencing

Ultimately, the court determined that Miranda'

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