Case Digest (G.R. No. 242414) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In an Information dated September 20, 2010, the People of the Philippines charged Mae Al-Saad y Bagkat with Arson with Homicide under Presidential Decree No. 1613, as amended. It was alleged that on September 14, 2010, at Lennox Anne Black Street, BF Resort Village, Talon 2, Las Piñas City, appellant willfully set fire to an inhabited house she resided in by spite. The blaze caused the deaths of her stepchildren Ameerah Nabil Al-Saad (14) and Ibrahim Nabil Al-Saad (12), serious injuries to Sarah Nabil Al-Saad (16), and property damage amounting to ₱1,500,000.00. Appellant pleaded not guilty on arraignment at the Regional Trial Court (RTC), Branch 199, on October 21, 2010. The prosecution presented twelve witnesses—including the victims’ father Nabil Al-Saad, surviving daughter Sarah, son Abdul, house helper Grace Daligdig, gasoline station personnel, a tricycle driver, barangay tanod, neighbors, NBI forensic chemist, and fire investigators—who testified to appellant’s movements Case Digest (G.R. No. 242414) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Trial
- On September 20, 2010, the Office of the Provincial Prosecutor of Cavite filed an Information against Mae Al-Saad y Bagkat for Arson with Homicide under Presidential Decree No. 1613, alleging that on September 14, 2010 in Las Piñas City she willfully set fire to an inhabited house, resulting in the death of two of her stepchildren (Ameerah, 14, and Ibrahim, 12) and serious injury to another (Sarah, 16), and property damage amounting to ₱1,500,000.
- Upon arraignment on October 21, 2010, accused-appellant pleaded not guilty. The prosecution presented 12 witnesses (including family members, neighbors, gasoline station personnel, and fire investigators), while the defense offered the accused as sole witness.
- Versions of the Parties
- Prosecution Version
- Around 1:00 a.m., the maid, Grace, was sent by Mae to buy milk and diapers; by 3:00 a.m. Mae procured 4.189 liters of gasoline from Optimus Shell Station and returned home with her child.
- The fire broke out shortly after; Abdul and Sarah Al-Saad escaped, but Ibrahim and Ameerah perished. Mae was seen at the guard house during the fire and was identified on CCTV buying gasoline. Forensic and fire experts found spalling indicative of accelerant use, though no electrical short was detected.
- Defense Version
- Mae denied setting the fire. She recounted a family misunderstanding on September 13, spent the night out, returned around midnight, smelled burning wiring, sent Grace on errands, then went out again at 3:00 a.m. to buy snacks and juice for her child.
- She claimed to have discovered the fire by accident, helped fetch water, and cooperated with firefighters.
- Lower Court Rulings
- RTC Decision (April 29, 2015)
- Convicted Mae of Arson with Homicide; sentenced her to reclusion perpetua and ordered her to indemnify each victim’s heirs ₱100,000.
- CA Decision (May 4, 2018)
- Affirmed the conviction; modified damages to ₱100,000 civil indemnity and ₱100,000 exemplary damages per heir, with 6% interest per annum from finality.
Issues:
- Whether the Court of Appeals gravely erred in affirming appellant’s conviction despite alleged insufficiency of proof beyond reasonable doubt.
- Whether the corpus delicti rule in arson and the requirements for circumstantial evidence were satisfied.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)