G.R. No. L-70222 February 27, 1987
People of the Philippines, plaintiff-appellee, vs. Juan Ancheta, accused-appellant.

FACTS

The accused-appellant, Juan Ancheta, was convicted of arson by the Regional Trial Court of Aparri, Cagayan, and sentenced to reclusion perpetua with civil indemnity. The prosecution evidence established that on the evening of August 25, 1980, in Gonzaga, Cagayan, Ancheta, appearing intoxicated, warned Teresa Gorospe and her neighbors to disperse because something would happen. Later that night, Ancheta and two companions forcibly entered Gorospe’s house, demanded money, and threatened to burn it. Gorospe escaped to seek help from the barangay captain. Upon their return, the house was already on fire. Witnesses, including Gorospe’s son Frederick, testified that one companion poured kerosene and ignited the house, and that Ancheta brandished a bolo to prevent people from extinguishing the blaze.
The defense presented a starkly different narrative. Ancheta claimed he and his brother-in-law were accosted by two armed strangers who manhandled him and forced him to accompany them. He alleged he was coerced into calling out to Gorospe’s house before the strangers entered. He testified he was taken away, heard a gunshot, saw the house on fire, and was then released after a warning. This account was corroborated by his brother-in-law, Feliciano Reynon. The trial court, however, found the defense story implausible, noting inconsistencies and unnatural conduct, such as Reynon not checking on Ancheta afterward despite the proximity of their homes.

ISSUE

The core issue is whether the trial court erred in convicting Juan Ancheta of arson based on the credibility of the prosecution witnesses over the defense’s claim of acting under compulsion.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial judge’s assessment of witness credibility, which is accorded great weight and respect on appeal absent a showing of grave abuse of discretion. The prosecution’s version was found substantially truthful despite minor inconsistencies, which did not detract from the core narrative of Ancheta’s direct participation in the arson. The Court rejected the defense of compulsion as incredible, describing Ancheta’s tale of coercion by mysterious strangers as unworthy of belief and severely straining credibility.
On the legal classification, the crime was properly characterized as arson under Article 321 of the Revised Penal Code, as the house was set on fire knowing it was occupied. The Court agreed with the appreciation of the aggravating circumstances of nighttime and evident premeditation, the latter inferred from the two-hour interval between the warning and the burning. Ancheta’s intoxication was neither aggravating nor mitigating. With these aggravating circumstances and no mitigating ones, the penalty of reclusion perpetua was correctly imposed. The civil indemnity of P40,000 was sustained, but the order for the Station Commander to share costs was deleted as he was not a party to the case.