Case Digest (G.R. No. 229103)
Facts:
People of the Philippines v. Richard Pugal y Austria, G.R. No. 229103, March 15, 2021, the Supreme Court Third Division, Leonen, J., writing for the Court.The case arose from an Information charging Richard A. Pugal with Destructive Arson under Article 320 of the Revised Penal Code for allegedly setting on fire FQ Grocery Store in Vigan City on January 1, 2009, causing the death of Florencio Que and the destruction of merchandise and the wooden building. Pugal pleaded not guilty at arraignment. During pre‑trial the parties stipulated to several facts, including the accused’s presence with a companion (Benjieboy Vicente) at the store, that Pugal was holding and lit a mother rocket (kwitis) which flew toward the fireworks display, that the incident occurred around midnight on New Year’s, and that the grocery store was licensed to sell fireworks.
Trial on the merits produced testimony from the store owners (Ferdinand and Franklin Que), a store helper (Reynante Rebamonte), and Police Officer Joseph Rivad. Their testimonies established that Vincente entered the store while Pugal remained outside holding a mother rocket, which he lit with a cigarette and directed toward the fireworks on display; the launched device ignited the store’s display, causing explosions and a fire that razed the wooden building and revealed the charred remains of Florencio inside. PO3 Rivad observed Franklin restraining Pugal, read him his rights, took him to the police station and to hospital for examination. Pugal waived presentation of evidence and filed only a memorandum.
On May 6, 2014, the Regional Trial Court (Branch 20, Ilocos Sur) convicted Pugal of Destructive Arson, finding intent from his external acts (lighting and directing the rocket toward the pyrotechnics), his attempt to flee instead of assisting victims, and his failure to apologize or return; the RTC sentenced him to reclusion perpetua without eligibility of parole and ordered awards of funeral and moral/temperate damages. The Court of Appeals (Special Eighth Division) affirmed the conviction but modified the damages award by adding civil indemnity, issuing its Decision on December 11, 2015. Pugal filed a Notice of Appeal; by Resolution dated February 3, 2016 the Court of Appeals gave due course and directed elevation of the records to the Supreme Court for further review. Both parties manifested they would not file supplemental briefs.
...(Pro-only)Issues:
- Was the accused-appellant’s intent to commit Destructive Arson proven beyond reasonable doubt?
- If not proven, does the circumstance that the accused had no intention to commit so grave a wrong mitigate or exempt his criminal liability under Articles 12(4), 13(3), or 67 of the...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)