Case Digest (A.M. No. RTJ-20-2579 [Formerly A.M. No. 20-06-75 RTC)
Facts:
Appellant Lao Wan Sing was convicted by the Court of First Instance of Aklan for arson, with the aggravating circumstance of taking advantage of the confusion occasioned by another fire, and was sentenced to reclusion perpetua, with indemnities to the listed fire victims. The case arose from two fires that broke out in Kalibo, Aklan on June 17, 1956: the first started at Juana’s Store on the western side of Rizal Street, spread to nearby stores and the Municipal Building, then died out; the second fire erupted from appellant’s kitchen on the eastern side of Rizal Street across the municipal building, spread extensively, and razed much of the business section.
The prosecution presented eyewitness accounts that appellant lighted and used kerosene and later poured kerosene to set his kitchen on fire. Appellant denied liability and claimed his conduct during the incident was consistent with evacuation and rescue efforts, while offering testimony he was effectively an onlooker. The trial court found the prosecution version credible and rejected the defense narrative and alleged alibi.
Issues:
- Whether the second fire was of incendiary character and actually started in appellant’s kitchen.
- Whether appellant was the one who set the fire in his kitchen.
- Whether the aggravating circumstance of taking advantage of confusion occasioned by another fire was properly appreciated.
- Whether the trial court erred in assessing the credibility of the witnesses and accepting the prosecution evidence despite alleged inconsistencies and delays.
Ruling:
The Supreme Court affirmed the trial court’s judgment in all respects, finding appellant guilty of arson with the aggravating circumstance.
The Court held that appellate review would not disturb credibility findings absent overlooked substantial facts, and it concluded that the evidence amply supported the prosecution’s account that the second fire was incendiary, unrelated to the first fire, and set by appellant.
Ratio:
The Court concurred with the trial court that the second fire could not have come from the first, citing the westward wind, the building layout and distance, and the lack of credible basis for theories that flares from nearby stores caused it. It further found sufficient evidence that the fire started in appellant’s kitchen and that appellant set it, relying on the testimony of Jose Narce, Guillermo Vidal, and Coronacion Penaflor, with Dr. Iluminado Motus providing corroboration.
On witness credibility, the Court agreed that delays in reporting were not inherently fatal given human reactions to stressful events, and it rejected the defense’s attempts to cast doubt on the witnesses’ motives and alleged inconsistencies as unpersuasive. It also upheld motive and the aggravating circumstance: evidence showed appellant’s store and goods were insured and that looting and confusion occurred during the fires, making it plausible that appellant took advantage of the turmoil to recover losses not covered by insurance.
Doctrine:
- When the credibility of witnesses is the central issue, appellate courts generally do not disturb the trial court’s findings because the trial court saw and heard the witnesses firsthand.
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