G.R. No. 248372 , August 27, 2020
People of the Philippines, Plaintiff-Appellee, vs. Aubrey Enriquez Soria, Accused-Appellant.

FACTS

Accused-appellant Aubrey Enriquez Soria was charged with Qualified Arson under P.D. No. 1613 (the New Arson Law). The Information alleged that on February 22, 2012, in Cebu City, she deliberately set fire to the inhabited house of Mariano Perez Parcon, Jr., resulting in its total burning and the death of house helper Cornelia O. Tagalog. Appellant pleaded not guilty.
The prosecution established that a fire destroyed the Parcon residence. Parcon testified he was awakened by smoke, and his family escaped, but Cornelia Tagalog died. A neighbor, Eduardo Umandak, encountered appellant around 4:00 a.m. near the scene carrying bags; she acted suspiciously and jumped a fence, leaving a travel bag behind. This bag was later identified as belonging to appellant. Appellant was found missing after the fire. Police arrested appellant in Minglanilla, Cebu, after she fled. Upon arrest, she was found in possession of a gray shoulder bag containing items identified as belonging to the deceased Cornelia Tagalog and two cellular phones identified as belonging to Parcon. News reporter Ryan Christopher Sorote testified that during an interview after her arrest, appellant admitted to the crime.
The defense claimed appellant had left the house earlier that night with Cornelia’s help because she wanted to go home to her sick children, and she denied setting the fire.
The Regional Trial Court convicted appellant of Qualified Arson, sentencing her to reclusion perpetua and ordering her to pay damages. The Court of Appeals affirmed the conviction with modifications to the damages. Appellant appealed to the Supreme Court, arguing the prosecution failed to prove her guilt beyond reasonable doubt, particularly contesting the sufficiency of the circumstantial evidence and the admissibility of her alleged admission to the reporter.

ISSUE

Whether the prosecution established the guilt of accused-appellant Aubrey Enriquez Soria for the crime charged beyond reasonable doubt.

RULING

The Supreme Court AFFIRMED the conviction but MODIFIED the damages. The Court held that the prosecution proved appellant’s guilt beyond reasonable doubt through circumstantial evidence. The concurrence of circumstances—(1) the fact of the fire; (2) appellant’s flight and possession of the victims’ properties shortly after the fire; (3) her admission to news reporter Sorote; and (4) her failure to report the fire or help the occupants—formed an unbroken chain leading to the conclusion that she intentionally set the fire. The Court found the admission to the reporter voluntary and admissible. The crime committed was properly classified as Arson with Homicide under P.D. No. 1613, as the intentional burning of an inhabited house resulted in death. The penalty of reclusion perpetua was affirmed. The Court modified the awarded damages: civil indemnity, moral damages, and exemplary damages to the heirs of Cornelia Tagalog were increased to Seventy-Five Thousand Pesos (P75,000.00) each; exemplary damages to Mariano Parcon, Jr. were increased to P75,000.00; and all monetary awards shall earn interest at 6% per annum from finality until fully paid.