G.R. No. 242414 , March 15, 2021
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MAE AL-SAAD Y BAGKAT, ACCUSED-APPELLANT.

FACTS

Accused-appellant Mae Al-Saad y Bagkat was charged with Arson with Homicide under Presidential Decree No. 1613. The Information alleged that on September 14, 2010, in Las Piñas City, motivated by spite or hatred, she willfully set fire to an inhabited house. On the occasion of the arson, her stepchildren Ameerah Nabil Al-Saad (14 years old) and Ibrahim Nabil Al-Saad (12 years old) died, and Sarah Nabil Al-Saad (16 years old) suffered serious physical injuries, with property damage estimated at Php 1,500,000.00.
The prosecution presented twelve witnesses. Their evidence established that: accused-appellant had a strained relationship with her stepson, Abdul Rahman Al-Saad, who managed the household finances; around 3:00 AM on September 14, 2010, she purchased 4.189 liters of unleaded gasoline from a Shell station, using a plastic soda bottle after being told kerosene was not for vehicles; CCTV footage and receipts confirmed the purchase; she was seen by a tricycle driver and a barangay tanod acting suspiciously before the fire; the fire engulfed the house, resulting in the deaths of Ameerah and Ibrahim and injuries to Sarah; the fire investigator noted spalling on concrete walls indicative of flammable substance use and found no electrical short circuit in the examined wiring; and the area where accused-appellant claimed to have seen an electrical spark was undamaged.
The defense presented only accused-appellant, who denied the accusations. She testified that she left the house around 3:00 AM to buy chocolates, juice, and cigarettes due to her crying child; she returned, and later, upon being alerted, discovered the house on fire.
The Regional Trial Court found accused-appellant guilty beyond reasonable doubt of Arson and sentenced her to Reclusion Perpetua, also ordering her to pay moral damages. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of Arson with Homicide.

RULING

The Supreme Court DISMISSED the appeal and AFFIRMED the conviction with MODIFICATION regarding damages. The Court held that the factual findings of the trial court, affirmed by the CA, are binding and conclusive. The prosecution successfully proved accused-appellant’s guilt beyond reasonable doubt. The evidence, including her purchase of gasoline shortly before the fire, her motive arising from family conflict, and the physical evidence ruling out accidental electrical fire, sufficiently established that she willfully set the fire. The penalty of Reclusion Perpetua was proper as two deaths resulted. However, pursuant to prevailing jurisprudence (People v. Soria and People v. Jugueta), the awards for damages were modified. Accused-appellant is ORDERED to pay the heirs of each deceased victim, Ameerah and Ibrahim, civil indemnity, moral damages, and exemplary damages of Php 75,000.00 each, with legal interest of 6% per annum from the finality of the judgment until fully paid.