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PEOPLE v. CARLITO DE LEON

FACTS:

On June 14, 1989, Gaudencio Legaspi, Carlito de Leon, Bien de Leon, Cornelio Cabildo, and Filoteo de Leon were charged with the crime of arson for burning Rafael Mercado's house. Gaudencio Legaspi died prior to his arraignment. The remaining appellants pleaded not guilty. Witnesses testified that on April 5, 1986, they saw the appellants approach the house and set it on fire. The sisters who witnessed the incident claimed that other valuables were lost in the fire. The police officer who conducted the investigation found remains of the burned hut at the scene. Appellants presented their own version of events, denying the charges. On December 14, 2001, the trial court found them guilty and sentenced them to a prison term of 10 years and 1 day to 14 years and one day. They appealed, and the Court of Appeals affirmed the decision with modification.

ISSUES:

  1. Whether the trial court erred in finding the accused guilty beyond reasonable doubt of the crime of arson.

  2. Whether the trial court erred in ordering the accused to pay the heirs of the private complainant damages.

RULING:

  1. The Court found that the trial court did not err in finding the accused guilty beyond reasonable doubt of the crime of arson. The prosecution was able to establish the guilt of the accused through the testimonies of the witnesses and the pieces of evidence presented, such as the photographs of the burnt hut. The fact that the accused were seen surrounding the hut and setting it on fire, as well as the previous incidents of destruction and threats, supported the finding of guilt beyond reasonable doubt.

  2. The Court affirmed the trial court's order for the accused to pay the heirs of the private complainant damages. The value of the burned hut, as determined by the complainants, was properly awarded to them as temperate damages. Additionally, the trial court correctly awarded exemplary damages to serve as a deterrent to future similar acts.

PRINCIPLES:

  • The guilt of the accused must be established beyond reasonable doubt through the testimonies of witnesses and pieces of evidence presented.

  • Damages may be awarded to the aggrieved party to compensate for the loss or harm suffered.

  • Exemplary damages may be awarded to deter the commission of similar acts in the future.