G.R. No. 182460 ; March 9, 2010
People of the Philippines, Plaintiff-Appellee, vs. Jessie Villegas Murcia, Accused-Appellant.

FACTS

Accused-appellant Jessie Villegas Murcia was charged with Arson (Criminal Case No. 2979-Bg) and Frustrated Homicide (Criminal Case No. 2980-Bg). The arson charge alleged that on March 24, 2004, in Bauang, La Union, he willfully set fire to a residential house inhabited by Felicidad M. Quilates, resulting in her death and the burning of nine neighboring houses. The frustrated homicide charge alleged that on the same date, with intent to kill, he stabbed Alicia Q. Manlupig, performing all acts of execution but her death was prevented by timely medical attendance.
The prosecution evidence established that appellant, the adopted son of Felicidad, was having a drinking spree with relatives, including Herminio Manlupig. An argument ensued between appellant and Herminio. Appellant went inside the house, emerged with a bolo, and chased Herminio, who escaped. Appellant returned inside. Shortly after, witnesses saw smoke coming from appellant’s room. Ricky Viduya saw appellant try to stab him, then stab Felicidad and Alicia. Herminio saw appellant burning clothes and boxes inside the house. Alicia testified she saw smoke, then appellant charged and stabbed her. Eulogio Quilates saw smoke and met appellant holding a knife. Appellant also attacked Herminio but was subdued. The fire razed eight houses. Felicidad died from burns. Appellant, as lone defense witness, admitted stabbing Alicia but denied setting the fire, claiming he lost consciousness after being struck.
The Regional Trial Court found appellant guilty beyond reasonable doubt of both charges, imposing the death penalty for arson and an indeterminate penalty for frustrated homicide. The Court of Appeals affirmed the conviction but modified the penalty for arson to reclusion perpetua. Appellant admitted the frustrated homicide charge, limiting the appeal to the arson conviction.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant Jessie Villegas Murcia committed the crime of arson.

RULING

Yes. The Supreme Court affirmed the conviction. The corpus delicti of arson (the fact of a fire caused by criminal agency) was established by photographs of the charred houses and testimonies. While no direct evidence linked appellant to the fire, his guilt was proven through circumstantial evidence meeting the requirements of Section 4, Rule 133 of the Rules of Court: (a) more than one circumstance; (b) proven facts from which inferences are derived; and (c) a combination of circumstances producing conviction beyond reasonable doubt.
The chain of circumstances established by the appellate court was: (1) appellant returned inside the house after chasing Herminio with a bolo; (2) smoke was seen coming from his room shortly after; (3) he was seen inside the house burning items; (4) he was met coming out of the burning house; (5) he was armed with a knife and was seen stabbing victims; and (6) he attempted to flee but was apprehended. These circumstances formed an unbroken chain leading to the logical conclusion that appellant started the fire.
The Court modified the awards of damages. For arson, appellant is ordered to pay the heirs of Felicidad Quilates ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages, and ₱25,000.00 as temperate damages (in lieu of actual damages). The award of ₱10,000.00 as actual damages was deleted. Appellant is also ordered to pay Eulogio Quilates ₱200,000.00 as temperate damages (in lieu of the deleted ₱250,000.00 actual damages). The penalty of reclusion perpetua without eligibility for parole under the Indeterminate Sentence Law was affirmed. The conviction for frustrated homicide and its penalties were also affirmed.