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PEOPLE v. EDGAR GUTIERREZ Y CORTEZ

## FACTS:

Edgar Gutierrez y Cortez is appealing a judgment convicting him of arson. The information against Gutierrez alleges that on December 14, 1989, he set fire to the house of Josefa Arroyo. The prosecution presented witnesses who testified that they saw Gutierrez throw a bag with what appeared to be gasoline at the house and then ignite it. Mario Alano, the owner of the house, testified that he heard Gutierrez threaten to blow up the house before seeing the wall catch fire. The police received a call regarding the arson incident and were directed to Gutierrez by Alano. In his defense, Gutierrez claimed alibi, stating that he was at another person's house after being injured in a fight.

## ISSUES:

  1. Whether the prosecution established the corpus delicti of arson sufficiently to secure the conviction of appellant Edgar Gutierrez y Cortez.

  2. Whether appellant’s defense of alibi could successfully negate the prosecution evidence and thereby warrant an acquittal.

  3. Whether the Trial Court correctly sentenced Gutierrez to reclusion perpetua for the crime of arson.

## RULING:

  1. The Supreme Court affirmed that the corpus delicti of arson was sufficiently established by eyewitness testimony and police reports. The testimonies of witnesses Felipe Enriquez and Mario Alano, combined with police blotters indicating the appellant's actions, formed credible evidence to support the conviction for arson.

  2. The Court rejected the defense of alibi presented by the appellant, considering the overwhelming evidence against him and the proximity which allowed for his participation in the crime. The essential elements to uphold the defense of alibi (distance and impossibility to be at the scene) were lacking.

  3. Regarding the sentence, the Supreme Court modified the ruling of the trial court. The trial court's imposition of reclusion perpetua was deemed improper. Instead, under the circumstances, the Supreme Court ruled that the appropriate penalty should be imprisonment ranging from a minimum of 2 years, 4 months, and 1 day of prision correccional to a maximum of 8 years and 1 day of prision mayor. They also deleted the P500.00 award for actual damages due to the hearsay nature of the cost estimate.

## PRINCIPLES:

  1. Corpus Delicti in Arson: Proof of corpus delicti in arson cases generally relies on demonstrating the occurrence of a fire and its intentional cause, as supported by credible eyewitness testimony even if uncorroborated.

  2. Overcoming Evidence with Alibi: Alibi as a defense must convincingly demonstrate the physical impossibility of the accused’s presence at the scene of the crime, which should be substantiated by clear and convincing evidence.

  3. Application of Indeterminate Sentence Law: In cases where there are neither aggravating nor mitigating circumstances, the Indeterminate Sentence Law applies, setting a range for minimum and maximum imprisonment terms depending on the nature of the crime and the periods stipulated by law.

  4. Evaluation of Sentencing and Aggravating Circumstances: Errors in sentencing or the misapprehension of aggravating factors lead to modification of the penalty upon appellate review to align with the documented facts and the appropriate legal standards.