G.R. No. 39086 ; October 26, 1934
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. ONG CHIAT LAY, ET AL., defendants. ONG CHIAT LAY, appellant.

FACTS

Appellant Ong Chiat Lay and two others were charged with arson for the burning of a building housing his store. After a joint trial, the two co-defendants were acquitted, but Ong Chiat Lay was convicted based on circumstantial evidence. The prosecution’s theory was that he conspired with or induced his co-defendants to commit the crime. The trial court cited circumstantial evidence such as his moving belongings before the fire, his absence during the fire, his indifference, and the presence of gasoline smells and empty gasoline cans.

ISSUE

Whether the circumstantial evidence presented was sufficient to establish the corpus delicti of arson and prove appellant’s guilt beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted appellant. The acquittal of the co-defendants negated the allegation of conspiracy or inducement, as one cannot be guilty of instigating a crime without proof that another actually committed it. The chain of circumstantial evidence was broken by this acquittal, making the evidence consistent with innocence and inconsistent with guilt beyond reasonable doubt. For conviction based on circumstantial evidence, the circumstances must form an unbroken chain leading to one reasonable conclusion of guilt to the exclusion of all others, which was not satisfied here.

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