G.R. No. 185282 ; September 24, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BENJAMIN BRAVO y ESTABILLO, Accused-Appellant.

FACTS

On August 10, 1989, at around 9:30 PM, the house of Mauro Camacho in Barangay Magungunay, Naguilian, La Union, was set on fire. The blaze resulted in the deaths of Mauro’s daughter-in-law, Shirley Camacho, and her four-month-old son, Jerickson. It also spread to and gutted the adjacent house of Dominador Camacho. Mauro Camacho testified that prior to the fire, he heard gunshots and the appellant, Benjamin Bravo, calling for him to come down. Bravo then went upstairs, pointed a gun at Mauro, and accused him of using witchcraft (“akusan”) on Bravo’s ailing father. When Mauro did not respond, Bravo left, uttering the threat, “I will burn you all. All of you will die.” Approximately fifteen seconds later, a fire erupted from the northwest portion of the second floor, where Shirley and Jerickson were located. Mauro and two of his children escaped by jumping out a window.
The defense presented an alibi. Appellant claimed he was in a different barangay accompanying his father for medical treatment on the night of the fire and only returned home the following day, where he was subsequently arrested. His father and cousin corroborated this story. The defense also presented character witnesses attesting to appellant’s good moral standing in the community.

ISSUE

Whether the guilt of the accused for the crime of arson was proven beyond reasonable doubt based on circumstantial evidence.

RULING

Yes. The Supreme Court affirmed the conviction, ruling that the totality of the circumstantial evidence presented by the prosecution sufficiently established appellant’s guilt beyond reasonable doubt. The Court meticulously applied the legal standard for circumstantial evidence, which requires that: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond moral certainty of the accused’s guilt.
The chain of circumstances was unbroken and conclusive. First, appellant had a clear motive, driven by anger and the belief that Mauro was practicing witchcraft against his father. Second, he was positively placed at the crime scene immediately before the fire, as testified to by Mauro. Third, he uttered a direct threat to burn the house moments before the conflagration began. Fourth, the fire started suspiciously soon after his departure and from the specific area he had just left. Fifth, another witness, Alejandro Marzan, saw appellant fleeing the area while carrying a gun. The Court found the collective weight of these facts incompatible with any reasonable hypothesis of innocence. The defense of alibi, uncorroborated by disinterested witnesses and inherently weak against positive identification, was correctly rejected. The penalty of reclusion perpetua and the awarded damages were affirmed.