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PEOPLE v. REYNALDO ABAYON Y APONTE

FACTS:

The case involves the appeal of accused-appellant Reynaldo Abayon y Aponte (Abayon) who was charged with arson resulting in multiple homicide. The information stated that on July 26, 2002, Abayon, with intent to cause damage to property, willfully and unlawfully burned the house of Roberto Ignacio and Teodoro Delos Angeles, resulting in the deaths of Lourdes Chokilo, Aiza Delos Angeles, and Zenaida Velos. Abayon pleaded not guilty and trial on the merits ensued. The prosecution presented evidence showing that Abayon and his wife had a quarrel, which was witnessed by their neighbors. Later that night, Abayon was seen holding an LPG gas tank and making statements suggesting he was going to start a fire. Robert Ignacio, Abayon's neighbor and best friend, scolded him and prevented him from carrying out his plan. However, the house caught fire later that night, resulting in the deaths of the three victims. Abayon denied causing the fire and raised the defense of alibi. The trial court found Abayon guilty beyond reasonable doubt, and the Court of Appeals affirmed the decision, upholding the conviction based on circumstantial evidence. Abayon appealed the CA decision.

ISSUES:

  1. Is there a complex crime of arson with homicide?

  2. Is circumstantial evidence sufficient to establish the guilt of the accused?

  3. Whether there is sufficient evidence to establish the guilt of the accused beyond reasonable doubt.

  4. Whether the identification of the accused as the perpetrator of the crime is credible.

  5. Whether temperate damages can be awarded when there is no competent proof of actual damages.

  6. Whether the court has the discretion to determine the amount of temperate damages.

RULING:

  1. There is no complex crime of arson with homicide. The crime of arson absorbs the resulting death or is a separate crime altogether. The main objective of the offender determines the crime committed. In this case, the objective of the accused was to destroy his family's apartment through arson, thus the resulting deaths are absorbed by the crime of arson.

  2. Circumstantial evidence is sufficient to establish the guilt of the accused. In the absence of direct evidence, circumstantial evidence may be used to sustain a conviction as long as there is more than one circumstance, the facts from which the inferences are derived have been proven, and the combination of all circumstances leads to a moral certainty that the accused is the one who committed the crime.

  3. Yes, there is sufficient evidence to establish the guilt of the accused beyond reasonable doubt. The combination of circumstantial evidence, including the motive, previous attempts to start a fire, and the statement made by the accused when buying a match, leads to the conclusion that the accused deliberately started the fire that resulted in the death of three victims.

  4. Yes, the identification of the accused as the perpetrator of the crime is credible. The court gives weight to the positive and categorical identification of the accused by the eyewitnesses over the accused's denial and alibi.

  5. Yes, temperate damages can be awarded when there is no competent proof of actual damages. According to Article 2224 of the Civil Code, temperate damages may be recovered when there is some pecuniary loss suffered but its amount cannot be proved with certainty.

  6. Yes, the court has the discretion to determine the amount of temperate damages. The determination of the temperate damages rests in the sound discretion of the courts.

PRINCIPLES:

  • There is no complex crime of arson with homicide. The crime of arson absorbs the resulting death or is a separate crime.

  • Circumstantial evidence may be sufficient to establish guilt as long as there is more than one circumstance, the proven facts support the inferences, and the combination of circumstances leads to moral certainty of the accused's guilt.

  • Denial cannot prevail over positive and categorical identification of the accused.

  • The trial court's assessment on the credibility of witnesses remains binding on an appellate tribunal, unless there are facts or circumstances of weight and influence that were overlooked and could affect the outcome of the case.

  • There are two types of positive identification: (1) direct evidence as an eyewitness to the very act of the commission of the crime, and (2) identification of a suspect as the perpetrator based on being last seen with the victim before and after the commission of the crime. The second type forms part of circumstantial evidence and, when taken 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.

  • The resort to circumstantial evidence to prove the identity of the accused, in the absence of direct evidence, is allowed to prevent felons from going free and to provide proper protection to the community.

  • In cases of arson resulting in death, the penalty is reclusion perpetua to death. Without any aggravating circumstance alleged, the penalty imposed is only reclusion perpetua.

  • Death indemnity, moral damages, and exemplary damages can be awarded to the victims' heirs. The amounts awarded may be increased based on precedent cases.

  • Temperate damages may be awarded when there is some pecuniary loss suffered but its amount cannot be proved with certainty.

  • The determination of the amount of temperate damages is within the court's discretion.