**Facts:**
1. **Incident Overview**:
– **Date & Location**: On the night of May 2, 1933, in Calapan, Mindoro, Philippines.
– **Act Committed**: Celerino Colocar allegedly set fire to a fish-net and a banca (boat) owned by Mauricio Ahorro.
2. **Witness Accounts**:
– **Pacifico Inato**:
– At around 1 AM, witnessed the fire from the shore and identified Colocar in the boat with a flashlight.
– Colocar, startled by the light, ran away from the scene.
– **Estanislao Acha & Francisco Avenilla**:
– Also saw the burning fish-net and boat at around 1 AM.
– Testified they saw Colocar walking away hastily from the burning boat.
3. **Damage Assessment**:
– Total damage was valued at P380 (P350 for the fish-net and P30 for the boat).
4. **Accused’s Defense**:
– Colocar denied the accusations asserting an alibi that he was asleep at home since 9:30 PM.
– Claimed that Avenilla was too drunk to have witnessed anything and Inato was physically incapable of being present due to illness.
**Procedural Posture:**
1. **Initial Trial**:
– Conducted in the Court of First Instance of Mindoro.
– **Verdict**: Colocar was found guilty of arson under Article 322(3) of the Revised Penal Code.
– **Sentence**: Two years, eleven months, and eleven days of prision correccional, and an indemnity of P380 to Ahorro.
2. **Appeal**:
– Filed by Colocar, asserting errors in the trial court’s judgment particularly relating to the credibility of witnesses and the sufficiency of evidence proving his guilt.
**Issues:**
1. **Credibility of Witnesses**:
– Whether the testimonies of Pacifico Inato and Estanislao Acha were credible and reliable enough to convict Colocar.
2. **Sufficiency of Evidence**:
– Whether the trial court erred in finding that Colocar deliberately set fire to the fish-net and banca.
3. **Aggravating Circumstance of Recidivism**:
– Legal interpretation of considering prior convictions as an aggravating circumstance despite the passage of time.
**Court’s Decision:**
1. **Credibility of Witnesses**:
– Supreme Court held there was no reason to disturb the trial court’s findings on the credibility of prosecution witnesses.
2. **Sufficiency of Evidence**:
– The Court upheld the trial court’s reliance on testimony and circumstantial evidence proving Colocar’s guilt beyond reasonable doubt.
3. **Aggravating Circumstance**:
– The Supreme Court affirmed that Colocar’s prior conviction (robbery in 1916) should be considered as an aggravating circumstance of recidivism despite the 16-year gap.
– The law does not specify a time limit after which a prior conviction cannot be considered for recidivism under the Revised Penal Code.
**Doctrine:**
– **Application of Recidivism**: The case affirms that recidivism as an aggravating circumstance has no temporal limitations under the Revised Penal Code of the Philippines.
– **Aggravating Circumstance**: Using a prior conviction for crimes within the same title (Title X of the Revised Penal Code) as an aggravating circumstance even after a significant lapse of time.
**Class Notes:**
– **Elements of Arson**:
1. **Intentional Act**: Setting fire to property (fish-net and banca in this case).
2. **Ownership & Damage**: The property damaged belonged to another person (Mauricio Ahorro), and the damage assessed.
– **Recidivism**:
– Defined as when a person on trial has a previous conviction for another offense included in the same title of the Penal Code.
– **Legal Statutes**: Ang 322(3) and Article 14 of the Revised Penal Code.
– **Prison Sentences**:
– Imposed penalties considering aggravating or mitigating circumstances under Article 89 and 90 of the Revised Penal Code.
**Historical Background:**
– The case contextualizes the post-colonial period in the Philippines, under American influence, reflecting a transitional justice system incorporating Spanish Penal Code with local specifics.
– Highlights societal emphasis on property protection and legal adherence to formalized codes under the Revised Penal Code, emphasizing legal continuity despite shifts in sovereign governance and the judicial system’s evolution.
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