G.R. No. 168050, September 19, 2008
People of the Philippines vs. Bernardino Gaffud, Jr.

FACTS

On the evening of May 10, 1994, the house of Manuel Salvador and his daughter Analyn in Nagtipunan, Quirino, was set on fire while they were inside, resulting in their deaths. Prosecution witness Orly Salvador testified that he heard gunshots, saw the house burning, and observed three individuals fleeing the scene. He positively identified one of them as the accused-appellant, Bernardino Gaffud, Jr., by the light of a flashlight the appellant was carrying. Barangay Captain Potado Ballang also testified that he saw Gaffud near the victim’s house earlier that evening under suspicious circumstances. The prosecution further established a possible motive through the testimony of Dominga Salvador, the victim’s wife, who indicated prior disputes between her husband and the appellant.
The defense presented alibi, claiming Gaffud was elsewhere during the incident. The Regional Trial Court convicted Gaffud of the complex crime of double murder and sentenced him to death. The Court of Appeals affirmed the conviction but modified the award of damages. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of double murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty and damages. The Court found the testimony of eyewitness Orly Salvador credible and sufficient to establish Gaffud’s presence and participation. His positive identification, made under adequate illumination from the burning house and the flashlight, prevailed over the weak defense of alibi. The Court ruled that the prosecution successfully proved all elements of murder through the qualifying circumstance of treachery, as the victims were attacked inside their home, rendered defenseless, and killed by means of fire. The act of setting the house ablaze constituted a single criminal impulse resulting in two deaths, justifying the complex crime of double murder.
However, pursuant to Republic Act No. 9346, which prohibits the death penalty, the Court reduced the sentence to reclusion perpetua without eligibility for parole. The civil indemnity was increased to P75,000 for each victim, and exemplary damages of P25,000 for each victim were awarded. The Court upheld the awards for moral and nominal damages. The decision was based on the totality of circumstantial evidence, credible eyewitness account, and the established motive, which collectively met the standard of proof beyond reasonable doubt.