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PEOPLE v. PEDRO CEDENIO Y RASONABLE

FACTS:

On November 26, 1986, a house owned by Hilario Dorio was deliberately set on fire. Witnesses observed Pedro Cedenio, Jurito Amarga, and Felipe Antipolo leaving the burning house carrying unsheathed cutting tools. The following morning, the remains of five members of the Dorio family, including a 22-day-old baby, were discovered in the burned house. Witnesses also saw Cedenio, Amarga, and Antipolo with bloodstained cutting tools. Another witness, Perfecto Antifuesto, claimed that Cedenio borrowed his cutting tool on the night before the incident and returned it with fresh bloodstains. The appellants were found guilty of arson with multiple murder by the trial court. They contended that there was no direct evidence connecting them to the killings and the house fire, asserting that their denial and alibi should take precedence over the prosecution's insufficient evidence. The court ruled that the appellants should be convicted of separate offenses of murder and arson instead, as there is no specific crime referred to as "Arson with Multiple Murder."

ISSUES:

  1. Whether the Information charging the appellants with multiple murder and arson violates the principle against multiplicity of charges.

  2. Whether the trial court erred in convicting appellants based on circumstantial evidence.

  3. Whether the crime committed is murder or homicide

  4. Whether the crime committed is arson resulting in death or just arson

  5. Whether the aggravating circumstance of evident premeditation is present

  6. Whether the non-registration of a lease agreement affects its validity.

  7. Whether the lessee is entitled to damages for the lessor's breach of contract.

RULING:

  1. The court held that the Information charging the appellants with multiple murder and arson does not violate the principle against multiplicity of charges. Although the Information erroneously labels the offense as "Arson with Multiple Murder," it actually charges appellants with six distinct criminal acts. Since appellants did not move to quash the information or object to it at any other time, the defect has been waived and the trial court may validly render judgment against them for as many crimes as were alleged.

  2. The court held that the trial court did not err in convicting appellants based on circumstantial evidence. While the prosecution witnesses did not see the actual killing of the victims and the burning of the house, guilt may still be established through circumstantial evidence. In this case, there were multiple circumstances that formed an unbroken chain leading to a fair and reasonable conclusion that appellants were the perpetrators of the crime. Therefore, the conviction based on circumstantial evidence is valid.

  3. The crime committed is murder. Since the appellants burned the victims' house after inflicting fatal wounds on them, it suggests that they clung to their determination to commit the crime. The appellants borrowed a bolo and later placated the lender when the bolo was returned bloodstained. This indicates that the appellants pondered on the means of executing the crime and the consequences of their criminal design. These circumstances established evident premeditation.

  4. The appellants can be held responsible for the murder of the four victims who sustained fatal wounds and for arson resulting in the death of the infant. The death certificates of the victims state that the cause of death for the four victims was "incised wounds" which could be caused by a bolo, while the infant's death was due to "burns." Hence, the appellants are guilty of arson and four counts of murder, and can be convicted of arson resulting in death, as defined in Sec. 5 of P.D. No. 1613.

  5. The aggravating circumstance of evident premeditation is present. The appellants definitely resolved to commit the offense, reflected on the means of carrying out their resolution, and an appreciable length of time elapsed for them to relent. Thus, the crime committed is aggravated by evident premeditation.

  6. No, the non-registration of a lease agreement does not affect its validity. Registration is not a requirement for the validity of a lease contract under Philippine law. Thus, the non-registration of the lease agreement does not render it void or unenforceable.

  7. Yes, the lessee is entitled to damages for the lessor's breach of contract. The lessor's failure to deliver the contracted premises to the lessee constitutes a breach of contract. As a result of the breach, the lessee is entitled to damages, which should be based on the actual loss suffered as a direct consequence of the breach.

PRINCIPLES:

  • When a defendant kills a person and then commits arson to cover up the killing, the defendant may be convicted of two separate crimes of either homicide or murder, and arson.

  • All allegations in the Information must be proven with moral certainty in order to sustain a conviction for as many offenses as are alleged.

  • Credence is accorded to the testimonies of prosecution witnesses, and the findings of the trial court are given great weight and respect when it had the opportunity to observe the witnesses.

  • When the defense fails to show any evil or improper motive on the part of prosecution witnesses, the presumption is that their testimonies are true and entitled to full faith and credence.

  • Guilt may be established through circumstantial evidence when there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all the circumstances is such as to produce conviction beyond reasonable doubt.

  • Conspiracy may be inferred from the acts of the accused when such acts point to a joint purpose or design.

  • Treachery cannot be presumed and must be proved by clear and convincing evidence.

  • Evident premeditation requires the affirmative appearance from the overt acts of the accused that they definitely resolved to commit the offense, reflected on the means of carrying out their resolution, and an appreciable length of time elapsed for them to relent.

  • The penalty for murder committed with evident premeditation is reclusion temporal in its maximum period to death, and for arson where death results, it is reclusion perpetua to death.

  • The civil action for recovery of civil liability is impliedly instituted with the criminal action if the heirs of the deceased did not waive or reserve their right to institute a civil action.

  • Non-registration of a lease agreement does not affect its validity.

  • The failure of the lessor to deliver the premises to the lessee constitutes a breach of contract.

  • A party who suffers a breach of contract is entitled to damages based on the actual loss suffered as a direct consequence of the breach.