G.R. No. 2158 : April 29, 1905
THE UNITED STATES, complainant-appellee, vs. JULIAN BUDIAO, ET AL., defendants-appellants.

FACTS:
On the evening of April 21, 1904, a sugar plantation in Sugud, Barrio of Calitan, Panay, Capiz, belonging to Pascual Barza, was burned, causing damages. The complaint charged defendants Julian Budiao and Bernabe Rojas with the crime of arson. It alleged that Budiao set fire to Barza’s plantation by order of Rojas. The trial court found both guilty and sentenced them to prision correccional and to jointly indemnify Barza. Only Bernabe Rojas appealed.

The prosecution’s case against Rojas rested almost entirely on the testimony of his co-defendant, Julian Budiao. Budiao testified that Rojas ordered him to set fire to Rojas’s own sugar cane plantation for cleaning purposes. Budiao claimed that while doing so, he was pursued by Barza and his workers, forcing him to flee and abandon the fire, which then spread to the adjacent plantation of Pascual Barza. Budiao consistently maintained, both at trial and in statements to the municipal president and police, that Rojas only instructed him to burn Rojas’s own property, not Barza’s. While some prosecution witnesses testified that Budiao implicated Rojas in setting Barza’s cane on fire, their accounts were inconsistent and contradicted by other witnesses, including the municipal president.

ISSUE:
Whether Bernabe Rojas is criminally liable for the arson of Pascual Barza’s sugar plantation based on the evidence presented.

RULING:
No. The Supreme Court reversed the judgment of conviction against appellant Bernabe Rojas and acquitted him.

The Court found that the evidence failed to establish Rojas’s criminal liability. The testimony of Julian Budiao, the principal witness, consistently indicated that Rojas ordered him to burn only Rojas’s own plantation. There was no proof that Rojas gave any order to burn Barza’s property or that he had a malicious intent to destroy Barza’s plantation through the fire set on his own land. The fact that the fire spread to Barza’s property was attributable to Budiao’s negligence or other circumstances during the event, for which Rojas could not be held criminally responsible. The alleged resentment between Rojas and Barza was insufficient to prove guilt beyond reasonable doubt.

The Court held that Rojas incurred no criminal liability for the arson. However, it reserved to Pascual Barza the right to pursue a separate civil action for damages against Rojas, which must be filed in the proper manner. The costs of the suit were declared de oficio as regards Rojas.