G.R. No. 3045
THE UNITED STATES, complainant-appellee, vs. TIBURCIO ZABALA, defendant-appellant.
September 8, 1906 | Tracey, J.

FACTS:
1. The accused, Tiburcio Zabala, while intoxicated and dissatisfied with his inheritance, set fire to his own house (his exclusive property) in an attempt to force a readjustment of relations with his brother.
2. The fire spread and consumed not only his residence but also an adjacent house owned by a relative, Mariano Tandoc, valued at 40 pesos.
3. Zabala’s house was occupied by himself and his son, while the neighbor’s house was vacant at the time.

ISSUE:
Whether Tiburcio Zabala is criminally liable for the burning of:
1. His own house (intentional arson);
2. The neighbor’s house (unintentional damage).

RULING:
1. No criminal liability for arson The majority held that Zabala did not commit arson because:
– He had no criminal intent (malice) in burning his own house.
– He did not foresee or intend the burning of his neighbor’s house.

2. Liable for reckless negligence (imprudencia temeraria) Under Article 568 of the Penal Code, Zabala’s act constituted criminal negligence, punishable as if it were a grave crime had it been done with malice.

DISPOSITION:
– Reversed the lower court’s sentence.
– Sentenced Zabala to:
– 6 months imprisonment (arresto mayor);
– Indemnification of 40 pesos to Mariano Tandoc (with subsidiary imprisonment if unpaid);
– Costs of the proceedings.

Concurring Justices: Arellano, C.J., Torres, Mapa, Carson, and Willard.

(Digest structured in FACTS, ISSUE, RULING format for clarity and legal precision.)