People v. de Leon

UNIVERSITY OF THE PHILIPPINES COLLEGE OF LAW Criminal Law 2
Lopez, Franco Luis G. (B2023) Prof. Augusto Arreza
People v. De Leon
G.R. No. 180762 (2009)
YNARES-SANTIAGO, J.
Articles invoked
Section 3, PD 1613, amending the law on arson

Sec. 3(2). Other Cases of Arson. – The penalty of reclusion temporal to reclusion perpetua shall be imposed if the
property burned is any of the following:
2. Any inhabited house or dwelling
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Section 4, PD 1613, amending the law on arson
If the crime of arson is committed by a syndicate, i.e., if it is planned or carried out by a group of three or more
persons, the penalty shall be imposed in its maximum period
FACTS OF THE CASE:
 This is an appeal from the Decision of the Court of Appeals which affirmed with modification the
Decision of the Regional Trial Court of Nueva Ecija finding herein appellants guilty beyond
reasonable doubt of the crime of arson and sentencing them to suffer the penalty of reclusion
perpetua and to pay the heirs of the private complainant P2,000.00 as temperate damages and
P20,000.00 as exemplary damages.
 At around 8:30 in the evening of April 5, 1986, Aquilina Mercado Rint (Aquilina) and her sister
Leonisa Mercado (Leonisa), together with their nephew Narciso Mercado, Jr., (Junior) were inside a
hut owned by their father.
 The loud and insistent barking of their dog prompted Aquilina to peep through the window and saw
five men approaching the premises whom she recognized as Gaudencio Legaspi and herein
appellants.
 Aquilina and Leonisa hurriedly went out of the hut and hid behind a pile of wood nearby while
Junior was dispatched to call for help.
 From their hiding place, they saw appellants surround the hut and set to fire the cogon roofing.
o While the hut was burning, Leonisa grabbed a flashlight from her sister and focused the same
at the group in order to see them more clearly.
o Upon seeing a light focused on them, Gaudencio ordered the others to leave and the men
immediately fled the premises.
o By the time Junior arrived with his uncles, the hut was already razed to the ground.
 Aquilina and Leonisa valued the hut at P3,000.00 and claimed that a pair of earrings, some beddings,
rice, P1,500.00 in cash and plenty of wood were also lost in the fire.
o They also testified that prior to the incident, appellants had been to the premises,
destroyed the plants, the fence and a hut which was first built therein.
o Appellants likewise physically attacked their father and issued threats that if he would not
give up his claim on the land, something untoward would happen to him; and that their father
Rafael filed several cases for Malicious Mischief, Forcible Entry and Serious Physical
Injuries against appellants.
 On the other hand, all appellants denied the charges against them.
 The trial court found them guilty beyond reasonable doubt for arson, and sentenced them to 1 day of
prison mayor, as minimum, to 14 years and one (1) day of reclusion temporal, as maximum, and to
pay jointly and severally the victims the sum of P3,000.00 representing the value of the burned hut.
 On appeal, the CA affirmed the trial court ruling with modification
o In lieu of the trial court’s sentenced, the CA imposed the penalty of reclusion perpetua, and
damages amounting to P22,000 (P2,000 as temperate damages and P20,000 as exemplary
damages)
 Hence the instant appeal
ISSUE
Whether or not the RTC erred in finding the petitioners guilty of arson
HELD
No, the lower court held correctly. Put simply, owing to the concurrence of the elements per the examinations of the
trial court, the Court exercised its respect for the former’s findings of fact.
Proof of the corpus delicti is indispensable in the prosecution of arson, as in all kinds of criminal offenses. Corpus
delicti means the substance of the crime; it is the fact that a crime has actually been committed.
In arson, the corpus delicti is generally satisfied by proof of the bare occurrence of the fire, e.g., the charred
remains of a house burned down and of its having been intentionally caused.
Even the uncorroborated testimony of a single eyewitness, if credible, may be enough to prove the corpus delicti and
to warrant conviction.32 The corpus delicti has been satisfactorily proven in the instant case.
ISSUE
Whether or not the CA erred in modifying the RTC’s imposed penalty
HELD
No, the appellate court held correctly, considering the presence of the special aggravating circumstance. The crime
was committed by a syndicate since it was carried out by a group of three or more persons
On the matter of damages, the appellate court also correctly awarded temperate damages and the exemplary damages,
of which the latter is especially appropriate given the presence of the aforesaid aggravating circumstance.
DISPOSITIVE PORTION
WHEREFORE, the instant appeal is DENIED. The Decision of the Court of Appeals in CA-G.R. CR No. 26390,
finding appellants Carlito de Leon, Bien de Leon, Cornelio Cabildo and Filoteo de Leon guilty beyond reasonable
doubt of the crime of arson, sentencing them to suffer the penalty reclusion perpetua and ordering them to pay the
heirs of private complainant Rafael Mercado P2,000.00 as temperate damages and P20,000.00 as exemplary damages,
is AFFIRMED.
SO ORDERED.

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UNIVERSITY OF THE PHILIPPINES COLLEGE OF LAW Criminal Law 2

Lopez, Franco Luis G. (B2023) Prof. Augusto Arreza

Section 3, PD 1613, amending the law on arson

FACTS OF THE CASE:

 On appeal, the CA affirmed the trial court ruling with modification

 Hence the instant appeal

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