G.R. No. L-54183 February 25, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO CRUZ y PERA, defendant-appellant.

FACTS

Reynaldo Cruz was a lessee occupying a portion of the ground floor of a two-story house owned by Gregorio Nacario in Davao City. Their relationship became severely strained due to a series of incidents: Cruz was scolded for burning a fetus in his kitchen after his wife’s miscarriage; he was reprimanded after a fire nearly burned the house’s toilet, which he was the last to use; and he was warned after Nacario’s grandchildren saw him in a compromising situation with another woman on the premises. By early May 1976, Cruz and Nacario were no longer on speaking terms. At around 4:00 AM on May 9, 1976, Nacario’s house was engulfed in fire. The blaze, which fire investigators determined was caused by inflammable materials like gasoline, completely destroyed the house and resulted in the deaths of Nacario’s daughter, two grandchildren, and a housemaid who were on the second floor.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Reynaldo Cruz was guilty of the crime of arson resulting in death.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s finding of guilt based on a combination of compelling circumstantial evidence. The legal logic rests on the sufficiency of circumstantial evidence to establish guilt when it leads to a fair and reasonable conclusion pointing to the accused as the perpetrator, to the exclusion of all others. The circumstances proven formed an unbroken chain: Cruz had a clear motive arising from the strained relations and repeated reprimands from Nacario. Immediately before the fire, a witness saw him standing at the back of the house and smelled gasoline, and then saw the house burning. Another witness saw Cruz hurriedly leaving the area as the fire started. His flight and evasion of arrest in Manila, including altering his appearance, further indicated consciousness of guilt. The Court found the defense of an accidental fire and the attempt to implicate another person to be unsupported by evidence. However, due to the lack of the necessary votes for its imposition, the death penalty was reduced to reclusion perpetua. The civil indemnity was also modified to P30,000.00 for each victim.