Case Digest (G.R. No. 188708) Core Legal Reasoning Model
Facts:
This case involves appellant Alamada Macabando, who was charged with destructive arson under Article 320 of the Revised Penal Code (RPC), as amended. The incident took place on December 21, 2001, in Barangay 35, Limketkai Drive, Cagayan de Oro City. At about 4:00 p.m., the appellant was seen acting violently—breaking bottles near his house while holding a G.I. pipe—and publicly threatening to retaliate and burn his house. By 6:35 p.m. that day, neighbors noticed smoke emanating from his two-storey house. When they attempted to put out the fire, the appellant, armed with a gun and a traveling bag, fired warning shots into the air and threatened to kill anyone who intervened. Witnesses confirmed his aggressive behavior and the intentional nature of the fire. Fire officers’ spot investigation concluded the fire was deliberately set in the appellant's house, which served as a residence, and spread to neighboring houses.
At trial, the appellant denied setting the fire, claiming
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Case Digest (G.R. No. 188708) Expanded Legal Reasoning Model
Facts:
- Context and Initial Incident
- On December 21, 2001, around 4:00 p.m., appellant Alamada Macabando was seen breaking bottles on the road near his house while holding a G.I. pipe and shouting threats to “get even.”
- The appellant also declared that he would burn his house.
- The Fire and Immediate Events
- At approximately 6:35 p.m. the same day, neighbors, including Cornelio Feliciano, noticed smoke coming from the appellant’s house. Cornelio attempted to douse the fire with water.
- Eric Quilantang, a neighbor living 10 meters from appellant’s house, fetched a fire extinguisher from the barangay headquarters.
- When Eric approached the burning house, the appellant, carrying a traveling bag and a gun, fired three shots in the air and warned that anyone who attempted to put out the fire would be killed.
- Following the gunshots, neighbors hastily protected their families and belongings.
- Investigation and Official Reports
- Fire Officers Victor Naive and Reynaldo Maliao conducted a spot investigation, concluding the fire originated from the appellant’s house and was intentionally set.
- Barangay Chairman Modesto Ligtas testified that the fire damaged many houses and aided City Social Welfare and Development Department personnel in damage assessment.
- Defense Testimony and Alternate Version
- The appellant claimed:
- He lived in the two-story house owned by his sister.
- He was angry earlier in the day due to the theft of a radio cassette but went to sleep thereafter.
- The fire had already started when he woke up.
- He denied threats, possession of a gun, and claimed the gunshots were from firecrackers.
- Supporting witnesses (the appellant’s cousin and brother-in-law) attested that he neither fired a gun nor was awake at the time the fire started.
- Procedural History
- The prosecution charged appellant with destructive arson under Article 320, Revised Penal Code (RPC), as amended.
- The appellant pleaded not guilty.
- The Regional Trial Court (RTC), Branch 25, Cagayan de Oro City, found the appellant guilty beyond reasonable doubt and sentenced him to reclusion perpetua.
- The Court of Appeals (CA) affirmed the RTC decision in toto.
Issues:
- Whether the prosecution established the guilt of appellant beyond reasonable doubt for destructive arson.
- Whether the evidence supports the conviction for destructive arson under Article 320 of the RPC or simple arson under Presidential Decree (P.D.) No. 1613.
- What penalty is proper to impose on appellant given the ruling on the crime committed.
- Whether the award of damages is justified under the circumstances.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)