G.R. No. 126517 November 24, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VIRGILIO SIGUIN y NAVAROSA, VICTOR SIGUIN y NAVAROSA and RAMON SIGUIN y NAVAROSA, accused, VIRGILIO SIGUIN y NAVAROSA, appellant.

FACTS

An Information for arson was filed against Virgilio, Victor, and Ramon Siguin, brothers of the deceased Joventino Siguin. The charge alleged that on February 27, 1994, in Quezon City, they conspired to set fire, using kerosene, to the houses of Peñaflor Bermudo, Daisy Ricafort, and Sylvia Gimpes, knowing the houses were occupied. The houses were completely destroyed. The complainants were neighbors of the Siguins. The arson occurred after the Siguin brothers learned that Joventino had been fatally shot within the Bermudo compound, with the husbands of complainants Sylvia Gimpes and Peñaflor Bermudo as suspects. Only Victor was initially arraigned and tried. Appellant Virgilio was later apprehended, arraigned, and, after adopting the evidence presented in Victor’s case with additional evidence, was tried. The trial court acquitted Victor but found Virgilio guilty beyond reasonable doubt of the crime of arson, sentencing him to reclusion perpetua and ordering him to pay actual damages to the complainants. Virgilio appealed.

ISSUE

The main issue is whether the prosecution proved the guilt of appellant Virgilio Siguin for the crime of arson beyond reasonable doubt.

RULING

The Supreme Court affirmed the trial court’s decision, finding appellant Virgilio Siguin guilty of arson. The Court reiterated the doctrines that: (1) factual findings of the trial court on witness credibility deserve great respect; (2) positive identification prevails over denial and alibi; and (3) testimonies of prosecution witnesses will be sustained despite imputation of ill motive if they are clear, consistent, and cohesive. The Court upheld the positive identification of Virgilio by prosecution witnesses Sylvia Gimpes and Peñaflor Bermudo, who saw him set their houses on fire. The Court found the witnesses’ testimonies credible and consistent on material points. It rejected Virgilio’s alibi that he was at the hospital attending to his dying brother at the time of the fire, noting it was not physically impossible for him to have been at the crime scene, as travel time was short. The Court also considered his failure to surrender for over a year after the case was filed as an indication of guilt. The crime was classified as destructive arson under Article 320 of the Revised Penal Code, as amended by Republic Act No. 7659 , punishable by reclusion perpetua to death. As no qualifying circumstance was proven, the penalty of reclusion perpetua was correctly imposed.