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PEOPLE v. BENJAMIN BRAVO Y ESTABILLO

FACTS:

Mauro Camacho and his family resided in Barangay Magungunay, Naguilian, La Union. On August 10, 1989, at around 9:30 p.m., Mauro heard gunshots followed by appellant Benjamin Bravo calling for him to come down. Appellant went upstairs, pointed a gun at Mauro, and demanded the akusan, accusing Mauro of putting a curse on his sick father. Mauro remained silent, prompting appellant to turn around. As appellant went down the stairs, he allegedly uttered threats of burning them all. Shortly after, Mauro saw a big fire on the second floor coming from the room of his daughter-in-law Shirley and grandson Jerickson. Mauro and his children were able to jump out of the window. Fidel Camacho, the husband of Mauro's daughter Merlita, arrived to find their house on fire. Appellant denied burning the house and gave an alibi, claiming he was in a different barangay with his family. After trial, appellant was found guilty of arson by the trial court.

The accused was charged with arson for allegedly setting houses on fire. The trial court relied on circumstantial evidence to convict the appellant of the crime. The appellate court affirmed the trial court's decision and awarded exemplary damages to the victim's surviving heir. The parties were required to submit their respective supplemental briefs but both opted to adopt their previous briefs. The appellant claimed alibi as his defense, supported by witnesses, and argued that the prosecution's evidence was merely circumstantial and insufficient to convict him. The Office of the Solicitor General (OSG) argued that the chain of events established the elements of the crime and identified the appellant as the arsonist. The OSG claimed that the appellant's alibi was weak.

The court explained that in a prosecution for arson, proof of the crime charged is complete when there is evidence of a fire caused by criminal agency and the identification of the defendant as responsible for the crime. While no direct evidence of the identity of the arsonist was presented, circumstantial evidence was sufficient for conviction as long as there were multiple circumstances, the facts from which the inferences were derived were proven, and the combination of all the circumstances produced a conviction beyond reasonable doubt. The court emphasized that direct evidence is not the only means of establishing guilt and that circumstantial evidence, together with other pieces of evidence, can lead to the conclusion that the accused is the author of the crime to the exclusion of all others.

ISSUES:

  1. Whether or not the circumstantial evidence presented in the case is enough to establish the guilt of the accused.

  2. Whether or not the testimonies of witnesses can be considered as positive identification of the accused.

  3. Whether the accused uttered unlawful threats before the fire broke out.

  4. Whether the accused was seen carrying a firearm before the fire broke out.

  5. Whether the defense of alibi is plausible and credible.

  6. Whether the appellant has proven the physical impossibility of his presence at the crime scene.

RULING:

  1. The Supreme Court ruled that the circumstantial evidence presented in the case, when taken together, forms an unbroken chain that points to no other than the accused as the arsonist. The combination of circumstances is such that it leaves no reasonable doubt as to the criminal responsibility of the accused. Therefore, the accused is guilty of the crime of arson.

  2. The accused was heard uttering threats before the fire broke out. The witness testified that the accused said, "I will burn your house. All of you will die." The witness also stated that fifteen seconds later, a big fire broke out. This shows a sufficient connection between the accused's threats and the fire.

  3. The accused was seen carrying a firearm before the fire broke out. The witness testified that while he was running towards the place of the fire, he encountered the accused running in the opposite direction and carrying a long firearm.

  4. The defense of alibi is not plausible and credible. Alibi becomes less plausible when it is corroborated by relatives and friends who may not be impartial witnesses. Alibi is inherently weak and unreliable in the face of positive and credible testimonies of prosecution witnesses.

  5. The appellant failed to prove the physical impossibility of his presence at the crime scene. The evidence on the alibi did not demonstrate the physical impossibility for the accused to be at the scene of the crime. The accused did not show that he was so far away and could not have been physically present at the place of the crime or its immediate vicinity at the time of its commission.

PRINCIPLES:

  • Circumstantial evidence, when taken together and forming an unbroken chain, can be sufficient to establish the guilt of the accused and justify a conviction.

  • Direct evidence of the commission of a crime is not the only basis for a trial court to find guilt; circumstantial evidence can also be used to prove the identity of the accused.

  • Positive identification of the accused can also be made through the testimonies of witnesses who have seen or interacted with the accused before and after the commission of the crime.

  • Uttering unlawful threats can be considered as evidence of a person's intent to commit a crime.

  • The presence of a firearm in the possession of a person can be an indication of their involvement in a crime, especially if the crime involves the use of a firearm.

  • Alibi is inherently weak and unreliable in the face of positive and credible testimonies of prosecution witnesses. It becomes less plausible, especially when it is corroborated by relatives and friends who may not be impartial witnesses.

  • Physical impossibility is essential in the defense of alibi. Physical impossibility refers to distance and the facility of access between the situs criminis and the location of the accused when the crime was committed. The accused must demonstrate that he was so far away and could not have been physically present at the scene of the crime and its immediate vicinity when the crime was committed.

  • For alibi to prosper, it is not enough that the accused was somewhere else when the crime was committed, but it must likewise be demonstrated that he was so far away that he could not have been physically present at the place of the crime or its immediate vicinity at the time of its commission.

  • Under Section 5 of Presidential Decree No. 1613, the penalty of reclusion perpetua to death is imposed when death results. However, in light of the passage of Republic Act No. 9346 prohibiting the imposition of the death penalty, the penalty shall be reclusion perpetua.

  • The award of damages may be affirmed.