GR 96713; (October, 1991) (Digest)
G.R. No. 96713 October 17, 1991
The People of the Philippines, plaintiff-appellee, vs. Orlando Arbolante y Lagundi, Teodulfo Lorenzo and Maximo Catabay, defendants. Teodulfo Lorenzo, defendant-appellant.
FACTS
On the evening of April 7, 1987, the house and rice granary of Albino Miranda in Tuao, Cagayan, were attacked by a group of about seventy armed individuals. The assailants fired upon the house, shouted for Miranda to surrender, and subsequently set fire to his granary. Miranda, who was inside with family members, witnessed accused Orlando Arbolante and appellant Teodulfo Lorenzo climb onto an extension roof, place bundles of cogon against the house, and ignite them, burning the house. Co-accused Maximo Catabay was present but seen merely standing. Miranda and his companions escaped only after the roof collapsed. The conflagration resulted in the total destruction of the house, granary, and numerous personal properties.
Accused Arbolante and appellant Lorenzo were charged with Arson under P.D. 1613. After trial, the Regional Trial Court found them guilty as principals and sentenced them to Reclusion Perpetua. They were also ordered to pay solidary civil liability. Lorenzo appealed the decision.
ISSUE
The core issue is whether the prosecution proved the guilt of appellant Teodulfo Lorenzo for the crime of Arson beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the establishment of conspiracy and the proper penalty. The Court found that the collective actions of the large armed group, including the specific overt acts of Arbolante and Lorenzo in directly setting the house ablaze, demonstrated a unity of purpose and a community of criminal design. Conspiracy having been proven, the act of one is the act of all, making Lorenzo equally liable as a principal.
Regarding the penalty, the Information alleged the crime was committed by a syndicate, a special aggravating circumstance under P.D. 1613 which warrants the imposition of the maximum period of the penalty. The trial court correctly imposed Reclusion Perpetua. However, the Court modified the award of civil damages. The total proven value of the burned properties amounted only to P153,000.00, not P153,980.00 as stated in the dispositive portion, as some claimed values were not fully substantiated by the evidence presented. The civil liability was accordingly reduced to this proven amount.