GR 154466; (January, 2008) (Digest)
G.R. No. 154466; January 28, 2008
CLIMACO AMORA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioner Climaco Amora leased a lot, built a bakery and residence on it, and entered into a contract stipulating that ownership of the building would transfer to the lessor upon the lease’s expiration on July 10, 1993. In January 1993, the lessor, Adelfa Maslog Tagaytay, informed petitioner she would not renew the lease. Shortly after, petitioner secured two fire insurance policies on the building totaling P450,000, a sum substantially higher than its P52,590 market value. On June 27, 1993, a fire originating from petitioner’s building gutted it and several nearby houses. Fire investigators concluded the fire was intentionally set. Petitioner was charged with Destructive Arson under P.D. No. 1613.
The Regional Trial Court convicted petitioner, a decision affirmed by the Court of Appeals. The CA found a chain of circumstantial evidence establishing guilt: motive from the impending lease termination; over-insurance of the property; petitioner’s presence at the scene before and during the fire; and the official finding of intentional ignition. Petitioner appealed, arguing the absence of direct evidence negates proof beyond reasonable doubt.
ISSUE
Whether the guilt of the petitioner for the crime of Destructive Arson was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. Direct evidence is not indispensable for a finding of guilt; circumstantial evidence suffices if it constitutes an unbroken chain leading to a fair and reasonable conclusion of the accused’s guilt. Here, the confluence of circumstances—motive, substantial over-insurance, petitioner’s presence, and the investigative conclusion of arson—forms a complete and consistent chain pointing to petitioner as the perpetrator.
The crime is properly classified as Destructive Arson under Section 2(7) of P.D. 1613, as the burned building was situated in a populated area and the fire spread to adjacent structures. Furthermore, the over-insurance created a prima facie evidence of arson under Section 6 of the same law, which petitioner failed to rebut. The penalty imposed by the CA, an indeterminate sentence of 12 years, 5 months, and 11 days of reclusion temporal, as minimum, to 18 years, 8 months, and 1 day of reclusion temporal, as maximum, was correctly computed in accordance with the Indeterminate Sentence Law and the rules for graduating penalties under the Revised Penal Code.