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Accused-Appellant.
G.R. No. 182460. March 9, 2010.
Facts:
This case is an appeal from a decision of the CA affirming with modification the decision of
RTC which found appellant Jessie Villegas Murcia guilty beyond reasonable doubt of the
crimes of arson and frustrated homicide.
On March 24, 2004 at around 3:30PM, appellant was having a drinking spree with his cousin
Herminio and two brothers in law in front of their house Bauang, La Union. Appellant and
Herminio were having an argument over the matter of caring for appellants mother, Felicidad
Quilantes. Apellant went inside the house to get a bolo, emerged from the house ten (10)
minutes later and ran after Herminio but the latter managed to escape.
After they were pacified, they resumed drinking. A few minutes later, Ricky, one of the brothers
in law, saw smoke coming from the room of the appellant. As Ricky was about to enter, he met
the appellant at the door. Ricky witnessed appellant stab Felicidad and Alicia. Herminio on the
other hand also saw the smoke, peeped through the small window of the house and
witnessed appellant burning some clothes and boxes in the sala.
Apellant was the lone witness for the defense. He later admitted to the crime of frustrated
homicide against Alicia but denied setting the house on fire. Appellant questions the credibility
of some witnesses and specifically imputes ill-motive on the part of Herminio testifying against
him. Also Apellant contends that the testimonies of the witnesesses as a whole failed prove
the identity of the perpetrator.
OSG on the other hand, banks on circumstantial evidence as relied by the trial court.
Issues:
1. Can the accused-appellant be convicted of arson even if no direct evidence was presented
against him?
2. Is the prosecution witness Herminio, credible nothwithstanding the fact that he and the
accused-appellant had a fight prior to the commission of the crime?
Ruling:
1. Yes. Direct evidence is not the sole means of establishing guilt beyond reasonable doubt.
Established facts that form a chain of circumstances can lead the mind intuitively or impel a
conscious process of reasoning towards a conviction. Indeed, rules on evidence and
principles in jurisprudence have long recognized that the accused may be convicted
through circumstantial evidence.
Section 4 of Rule 133 of the Rules of Court provides: