GR L 1296; (October, 1903) (Digest)
G.R. No. L-1296 : October 26, 1903
THE UNITED STATES, complainant-appellee, vs. GREGORIO MIRANDA, defendant-appellant.
FACTS:
Gregorio Miranda was charged with burning a banca (boat) owned by Luis Yanco and anchored in Biñan. Miranda was the municipal inspector of bancas and also operated his own banca. Evidence showed he had an existing enmity with the crew of Yanco’s banca, having previously caused their arrest for ordinance violations. On the day of the fire, December 31, Miranda threatened the banca’s pilot, stating something would happen to the banca and the pilot if his instructions were not followed. That night, the banca was destroyed by a fire of incendiary origin, evidenced by dried cane branches and the odor of petroleum near the scene. Miranda, despite his duty as inspector to watch over the bancas and his house being within sight of the fire, did not go to the scene upon hearing the alarm and failed to report for duty the next day. In his testimony, he gave contradictory statements about his knowledge of the fire and his whereabouts.
ISSUE:
Was the circumstantial evidence presented sufficient to prove beyond a reasonable doubt that Gregorio Miranda was guilty of burning the banca?
RULING:
Yes. The Supreme Court affirmed the conviction, holding that the totality of the circumstantial evidence was sufficient to establish Miranda’s guilt beyond a reasonable doubt. The Court considered the following circumstances: (1) Miranda’s motive arising from enmity and business competition with the banca’s operators; (2) his direct threat made on the day of the fire; (3) the incendiary nature of the fire; (4) his failure, as inspector, to go to the fire scene or perform his duties the following day despite being nearby; and (5) the contradictory and evasive nature of his testimony. The Court modified the trial court’s judgment by imposing subsidiary imprisonment in case of insolvency for the payment of the indemnity to the banca’s owner, in addition to the costs. Miranda was sentenced to six months and one day of prision correccional, an indemnity of 1,000 pesos, and costs, with corresponding subsidiary imprisonment in case of insolvency.