M-Jay T.

Otiz
Bscrim 3GE
GR No. 159950

In this case, Joel P. Gonzales Jr. was found guilty by the Supreme Court of the Philippines for
the crime of arson. The fire destroyed a two-storey residential building which was partitioned
into dwellings and rented out to tenants.

Facts:

•Gonzales Jr. was seen arguing with his aunt before the fire.
•An eyewitness testified that they saw Gonzales Jr. ignite a flame and throw it on a pile of
clothes in the middle of the living room.
•Fire quickly spread to the other parts of the building.
•A Physical Science Report showed that no flammable substance was found in the ashes.
•Gonzales Jr. denied the allegations and said the fire was caused by faulty electrical wiring.

Issue:

Whether the discrepancies between the witness' affidavit and court testimony are enough to
acquit Gonzales Jr.

Ruling:

The Supreme Court found Gonzales Jr. guilty. The court believes that the witness' testimony
in court is more credible than the affidavit because affidavits are generally considered inferior
to testimonies given in open court. The findings of the Physical Science Report, which is
negative evidence, is outweighed by the positive identification of the witness.

Penalty:

•Imprisonment of nine (9) years and one (1) day of prision mayor as minimum, to twenty (20)
years of reclusion temporal as maximum
•Temperate damages₱500,000 to Carlos C. Canlas,₱100,000 each to Francis F. Simpao and
Andres V. Villaflor
•Exemplary damages of ₱50,000 to each of Carlos C. Canlas, Francis F. Simpao and Andres
V. Villaflor
 GR No. 204891

People vs. Reynaldo Abayon y Aponte (G.R. No. 204891)

Accused: Reynaldo Abayon y Aponte

Crime Charged: Arson resulting in multiple homicide

Facts:
• Abayon argued with his wife.
• Neighbors saw Abayon holding an LPG tank and muttering about being useless.
• Abayon's neighbor stopped him from lighting the gas tank.
• Later that night, a fire broke out in Abayon's apartment and engulfed neighboring units,
killing 3 people.
•Abayon claimed alibi but presented no witnesses.

Issue:
• Whether Abayon is guilty of arson resulting in multiple homicide.

Ruling:
Guilty. The court established Abayon's guilt through circumstantial evidence:
* The fight with his wife.
* Threatening to burn the house with the gas tank.
* Buying matches just before the fire.
• Abayon's alibi was uncorroborated and outweighed by neighbors' testimonies.
•The proper penalty is reclusion perpetua (life imprisonment).

Additional Orders:
• Abayon is to pay P75,000 civil indemnity to each victim's heirs.
• Abayon is to pay P75,000 moral damages and P75,000 exemplary damages to each victim's
heirs.
• Abayon is to pay temperate damages:
* P100,000 to the Chokilo family
* P50,000 to the Ignacio family
* P50,000 to the Balbas family
• Interest of 6% per annum on all awarded amounts starts from the finality of the decision.

Reasoning:
• The fire resulted in deaths but arson is still the main crime as Abayon's intent was to burn
his apartment. The deaths are absorbed by the arson charge.
•The prosecution established circumstantial evidence to prove Abayon's guilt beyond
reasonable doubt.
•Witness testimonies, though not direct evidence of Abayon starting the fire, point to his
motive and opportunity.

GR No. 188708

People vs. Alamada Macabando (G.R. No. 188708)

Accused:Alamada Macabando

Crime Charged: Destructive Arson (originally) - Modified to Simple Arson

Facts:

• Macabando argued with someone and threatened to burn his house.

• He was later seen acting violently and breaking bottles near his house.
• A fire broke out in his house shortly after.
• Macabando prevented people from extinguishing the fire and fired gunshots in the air.
• Fire investigation revealed the fire originated in Macabando's house and was intentional.

Issue:

•Whether Macabando is guilty of destructive arson.

Ruling:

• Macabando was found guilty of SIMPLE ARSON, not destructive arson.

• The court relied on circumstantial evidence to prove Macabando's guilt.
• The fire only spread to neighboring houses unintentionally.
• Simple arson carries a lesser penalty than destructive arson.
• Macabando received a sentence of 10 years and 1 day to 16 years and 1 day imprisonment.

Reasoning:

• The court believed the prosecution's witnesses and the fire investigation report.
• Macabando's actions of preventing the fire from being extinguished and firing gunshots
pointed to his guilt.
• Destructive arson requires a greater degree of perversity, which wasn't present in this case.

Note:

• The case highlights the use of circumstantial evidence to convict a suspect.

• It also clarifies the distinction between simple arson and destructive arson based on the
offender's intent and the consequences of the act.
 GR No. 163938
Dante Buebos et al. vs. People of the Philippines

Accused: Dante Buebos and Sarmelito Buebos

Crime: Arson

Facts:

• Adelina Borbe woke up to noise outside her house in the middle of the night.
• She saw the four accused, including Dante and Sarmelito Buebos, standing in front of her
house.
• Moments later, the roof of her house caught fire.
• The accused fled the scene while Adelina shouted for help.

Issue:

•Whether the accused were guilty of arson based on circumstantial evidence.

Ruling:

• Yes. The court found the accused guilty of arson based on circumstantial evidence.
• The series of events - the accused being outside the house at night, the fire starting right
after they were seen, and their flight from the scene - formed a chain of circumstances that
pointed to their guilt.

Reasoning:

• The court established that circumstantial evidence can be sufficient for a conviction if it
meets three criteria:
• There is more than one piece of evidence.
• The evidence is proven to be true.
• The combination of evidence leads to a moral certainty that the accused committed the
crime.
In this case, the court found that the evidence met all three criteria.

Additional Points:

•The court also found the accused guilty of conspiracy based on their coordinated actions.
•The penalty for the crime was downgraded from burning of an inhabited house to simple
arson because the information did not specifically allege the former.