G.R. No. 229103 , March 15, 2021
People of the Philippines, Plaintiff-Appellee, vs. Richard Pugal y Austria, Accused-Appellant.

FACTS

Accused-appellant Richard Pugal was charged with Destructive Arson under Article 320 of the Revised Penal Code. The Information alleged that on January 1, 2009, in Vigan City, Ilocos Sur, he willfully set fire to the FQ Store, an inhabited place and storehouse of inflammable materials, by using a “mother rocket” or “kwitis” directed at the merchandise, causing an explosion, burning, and the death of owner Florencio Que. During pre-trial, the parties stipulated, among others, that Pugal arrived at the store holding a mother rocket, lit it, and the incident occurred around midnight on New Year’s Day. Trial evidence established that Pugal, while outside the store, lit the firework with his cigarette while it was slanted towards the store’s fireworks display, said “Happy New Year,” and launched it. The rocket flew towards the store’s displayed mother rocket, causing sparks that ignited other fireworks. The wooden building was razed, and Florencio Que’s charred remains were found inside. Pugal attempted to escape but was subdued. He waived his right to present evidence. The Regional Trial Court convicted him of destructive arson, sentencing him to reclusion perpetua without parole and ordering him to pay damages. The Court of Appeals affirmed the conviction but modified the damages. Pugal appealed, arguing lack of intent.

ISSUE

Whether the prosecution proved beyond reasonable doubt the intent to commit the crime of destructive arson.

RULING

Yes. The Supreme Court affirmed the conviction. Intent, being a mental state, is deduced from external acts. Pugal’s deliberate act of lighting a mother rocket and directing it towards the store’s fireworks display, which contained inflammable materials, demonstrated a reckless disregard for lives and property. The natural and probable consequence of his act was the fire that burned the store and caused a death. His claim of lack of intent was negated by his actions: he pointed the rocket at the display, attempted to flee after the fire instead of helping, and presented no evidence of motive or accident. The circumstances he cited (e.g., celebratory context, alleged improper handling, lack of prior knowledge of the victims) do not disprove intent. The Court also found no mitigating circumstance of “lack of intent to commit so grave a wrong” under Article 13(3) of the Revised Penal Code, as the means employed (lighting a rocket near inflammables) were reasonably sufficient to produce the consequential fire and death. His flight, though not conclusive proof of guilt, is admissible evidence consistent with guilt when not satisfactorily explained. Thus, all elements of destructive arson were proven beyond reasonable doubt.