EDUARDO LEYSON, ET AL., petitioners, vs. PEDRO LAWA, ET AL., and THE COURT OF APPEALS, respondents.
FACTS
Petitioners, led by ranch owner Eduardo Leyson, were charged with arson for allegedly setting fire to thirteen houses belonging to members of the B’laan tribe on September 7, 1996. The private respondents were farmers whom Leyson had previously allowed to cultivate portions of his land in exchange for a share of their produce. After a dispute arose, Leyson demanded they vacate the property. The prosecution presented eyewitnesses, including Romeo Jarmin, who testified that they saw Leyson and his armed farmhands arrive at the ranch, fire shots, and subsequently set the houses ablaze, causing damage totaling approximately P468,490.00.
The defense presented alibis and claimed the witnesses were biased due to the land dispute. The Regional Trial Court convicted all petitioners. On appeal, the Court of Appeals affirmed the conviction of the farmhands (Eduardo Bantulo, Dominador Bantulo, Eduardo Padayag, Eddie Padayag, and Rodolfo Padayag) but acquitted Eduardo Leyson, Sr. on reasonable doubt, citing insufficient evidence of his direct participation in the burning. However, the CA upheld Leyson’s civil liability to pay damages to the private respondents.
ISSUE
Whether the Court of Appeals erred in: (1) affirming the conviction of the farmhand-petitioners for arson; and (2) holding petitioner Eduardo Leyson, Sr. civilly liable for damages despite his acquittal.
RULING
The Supreme Court denied the petition and affirmed the CA decision. On the first issue, the conviction of the farmhands was upheld. The Court found the testimonies of prosecution witnesses credible, consistent, and sufficient to establish guilt beyond reasonable doubt. The positive identification of the petitioners as the perpetrators, who were seen firing weapons and setting the houses on fire, prevailed over their weak alibis. The alleged bias of the witnesses did not destroy their credibility, as their testimonies were corroborated on material points.
On the second issue, the Court ruled that Leyson’s acquittal based on reasonable doubt did not extinguish his civil liability. The civil action in this case was impliedly instituted with the criminal action. The acquittal was grounded on the failure to prove his criminal participation beyond reasonable doubt, not on a finding that the damaging fire did not occur. Since the fact of burning and the resulting damage were proven, and considering Leyson had previously obligated himself to pay for damages, the civil liability based on quasi-delict or other sources of obligation remained. The Court emphasized that acquittal on reasonable doubt is not a bar to the award of civil damages where the facts establish a preponderance of evidence for such liability.
