G.R. No. 76005 - People vs. Exala

On June 26, 1997, a two‐storey residential building in Quezon City, Philippines—owned and occupied by Carlos C. Canlas and partially rented out—was set on fire.
The Information, dated July 24, 1997, charged petitioner Joel P. Gonzales, Jr. with arson, alleging that he wilfully, unlawfully, and feloniously set fire to the building and several adjacent properties, with total damages amounting to P5,465,000.00.
The properties affected belonged not only to Canlas but to various owners, with values listed in the charge, stressing the gravity of the widespread damage.

Canlas recounted that while watching television, he was alerted by his daughter about a commotion in an adjacent room.
Upon investigation, he detected a smell of gas, saw Gonzales ignite a flame, and observed him throwing it on a pile of clothes near an LPG tank, which rapidly led to a spreading fire.

Andres V. Villaflor testified that he heard Gonzales and his aunt quarreling and later heard Gonzales exclaim, “Susunugin ko itong bahay na ito!”
Francis F. Simpao confirmed observing the fire emanating from Gonzales’ room and noted that Gonzales was laughing while the building burned.

Police Officer Alejandro Mendoza testified that upon arrival at the scene, he obtained an admission from Gonzales acknowledging responsibility for the fire.

Gonzales claimed that the fire was due to faulty electrical wiring, stating that he was asleep until he was awakened by the heat of the room in flames.
He denied any quarrel with his aunt, attributing his loud voice to her partial deafness, and maintained that he only requested her to buy food due to the lack of M-Gas LPG.
The defense also presented a Physical Science Report from Police Inspector Grace M. Eustaquio indicating that the ashes were negative for flammable substances.

The Regional Trial Court (RTC) of Quezon City, Branch 97, convicted Gonzales on May 28, 1998, finding him guilty beyond reasonable doubt, and sentenced him to a penal range of 12 years (minimum) to 17 years and 4 months (maximum) imprisonment under prision mayor and reclusion temporal, respectively.
Civil liability was addressed by awarding nominal damages of P10,000.00 each to the private complainants.
On appeal, the Court of Appeals (CA) affirmed the trial court’s decision, holding that:

The discrepancies between Canlas’s affidavits and his in-court testimony were minor and did not undermine his overall credibility.
The circumstantial evidence, coupled with the eyewitness identification, was sufficient to sustain the conviction for arson.

Petitioner Gonzales argued that the Court of Appeals erred in giving effect to the positive identification of Canlas despite material discrepancies between his sworn affidavits and his court testimony.
He also raised objections to the reliance on other prosecution witnesses and the rejection of the Physical Science Report which stated that no flammable substance was detected in the ashes.
Furthermore, the petitioner contended that his prior threats to burn the house did not constitute a real intent, seeking to discredit the credibility of the prosecution’s evidence.

Whether the Court of Appeals correctly concluded that no serious reversible error or grave abuse of discretion occurred in the trial court’s findings despite the material discrepancies between the prosecution witnesses’ affidavits and their in-court testimonies.
Whether, given the evidence presented—including the eyewitness identification and circumstantial evidence—the conviction for arson under Section 3(2) of Presidential Decree No. 1613, as well as the concomitant penalties and damages, was rightly affirmed.