G.R. No. L-9398; August 22, 1914
THE UNITED STATES, plaintiff-appellee, vs. AMADO ESMUNDO, defendant-appellant.

FACTS:
The accused, Amado Esmundo, was convicted in the Court of First Instance of Nueva Ecija for the crime of arson. The information alleged that on or about the night of April 30, 1913, he maliciously set fire to two warehouses owned by Jacobo Selzer in the barrio of Luyos, San Antonio, Nueva Ecija, causing damage estimated at P8,320. The prosecution presented evidence showing that on the afternoon of the fire, Esmundo was seen near the warehouses inquiring if the owner was home and was told the owner was away. After the fire started, witnesses saw Esmundo running away from the burning warehouses. The defense presented no evidence. The trial court convicted Esmundo, sentencing him to eight years and one day of imprisonment, indemnification, and subsidiary imprisonment in case of insolvency.

ISSUE:
Whether the evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that the accused committed the crime of arson.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted the accused. The Court held that the prosecution failed to establish two essential elements: (1) that the fire was of malicious or criminal origin (as opposed to accidental), and (2) that the accused was the perpetrator. The evidence merely placed the accused near the vicinity before and after the fire, which is insufficient to prove guilt. No evidence of motive was presented, and the accused’s failure to testify in his defense cannot give rise to an inference of guilt, as the burden of proof remains with the prosecution. The Court emphasized the importance of proving motive in criminal cases, not as an indispensable element, but as a vital aid in establishing the commission of the crime by the accused. Since the prosecution’s evidence was wholly inadequate to sustain a conviction, the accused is entitled to an acquittal. Costs were ordered de oficio.