G.R. No. 229103 - People vs. Pugal y Austria

Richard Pugal y Austria was charged with destructive arson under Article 320 of the Revised Penal Code for allegedly setting fire to the FQ Store, owned by Florencio Que y Sy, on January 1, 2009, in Vigan City, Ilocos Sur.
The fire caused an explosion and destroyed merchandise worth approximately P3,000,000 and the building itself. It resulted in the death of Florencio Que y Sy.
Pugal pleaded not guilty during arraignment.

The court's jurisdiction and the identity of the accused were admitted.
The accused resided in Barangay Capangpangan, Vigan City.
On the night of the incident, Pugal was holding a "mother rocket" or "kwitis" firework when he arrived at FQ Store accompanied by Benjieboy Vicente.
Pugal lit the mother rocket near the store around midnight on New Year’s Day.
It was usual to see people with firecrackers due to the New Year celebration.
The accused and the victim did not personally know each other.
Benjieboy Vicente entered the store to buy cigarettes.

Ferdinand and Franklin Que, store owners, and Reynante Rebamonte, a store helper, testified regarding the events.
Around 11:00 p.m. on December 31, 2008, Ferdinand and Franklin attended their licensed fireworks-selling store.
Pugal held a lit mother rocket oriented toward the display of fireworks in front of the store and lit its fuse with a cigarette.
He greeted “Happy New Year!” before lighting the firework.
Franklin attempted to stop Pugal but to no avail as the firework flew toward the store’s mother rocket display, causing sparks that ignited the store’s pyrotechnics, leading to an explosion and fire.
The wooden store was easily consumed by fire.
Pugal tried to escape but was restrained by Franklin and Reynante.
Police Officer 3 Joseph Rivad arrived at the scene, saw Pugal restrained, informed him of his rights, and brought him to the police station and later to a hospital for medical examination.
The charred remains of Florencio Que were found inside the store.
Pugal waived presenting evidence and filed a memorandum instead.

On May 6, 2014, the Regional Trial Court (RTC), Branch 20 of Ilocos Sur, convicted Pugal of destructive arson, holding that intent was proven by his deliberate ignition and direction of the firework toward the store’s combustible materials.
The RTC sentenced Pugal to reclusion perpetua without eligibility for parole and ordered him to pay funeral expenses, moral damages, and temperate damages to the heirs of Florencio Que.
On appeal, the Court of Appeals (CA) affirmed the conviction and added civil indemnity of P75,000 to the damages awarded.
CA found intent proven beyond reasonable doubt based on the accused’s deliberate act which caused the death of Florencio Que and destruction of the property.
Pugal filed a notice of appeal to the Supreme Court (SC), which eventually took up the case.

The rocket was aimed at fireworks near, but not inside, the store.
He lacked skill in handling mother rockets; it exploded in his hands.
Lighting the rocket was a celebratory spontaneous act for New Year’s Day.
Franklin’s warning came too late and there was no evidence Pugal understood it.
No motive existed to cause damage or harm; he did not personally know the store owners.
Running away and failing to help was a normal human reaction.
Alleged inconsistency in RTC’s finding that Pugal both intended a joke and committed intentional arson.

Asserted that the fire was an accident exempting him from criminal liability (RPC Article 12, Sec. 4), or at least meriting mitigation (Articles 13(3) and 67 of the RPC).

Whether the accused-appellant Richard Pugal is guilty of destructive arson.
Whether the prosecution proved beyond reasonable doubt the presence of intent to commit destructive arson.
Whether the mitigating circumstance of lack of intent to commit so grave a wrong (Article 13(3) RPC) applies or the accused qualifies for exemption under Article 12(4) and penalty reduction under Article 67 of the Revised Penal Code.