Case Digest (G.R. No. 248372)
Facts:
In People of the Philippines v. Aubrey Enriquez Soria (G.R. No. 248372, August 27, 2020; Decision promulgated October 3, 2022), the appellant Aubrey Enriquez Soria was charged with Qualified Arson with Homicide under Section 1 in relation to Section 5 of Presidential Decree No. 1613 for deliberately setting fire to an inhabited house owned by Mariano Pérez Parcon, Jr. in Holy Family Village, Barangay Banilad, Cebu City on February 22, 2012. The blaze destroyed the dwelling and its contents, causing damages of ₱2,649,048.72, and resulted in the death of Cornelia O. Tagalog, a household helper. At trial, the prosecution relied on a chain of circumstantial evidence: the victim’s husband, Parcon, detected smoke at around 2 a.m.; a neighbor, Eduardo Umandak, encountered a fleeing woman carrying personal effects later identified as belonging to Soria and the deceased; police recovered the victim’s and employer’s cellphones and other items from the appellant; and a media report by RyanCase Digest (G.R. No. 248372)
Facts:
- Background and Charges
- On February 27, 2012, an Information was filed against Aubrey Enriquez Soria for Qualified Arson under Section 1 in relation to Section 5 of Presidential Decree No. 1613, alleging that on February 22, 2012 at about 2:06 a.m. she set fire to an inhabited house in Holy Family Village, Barangay Banilad, Cebu City, causing total destruction of the house and the death of house helper Cornelia O. Tagalog. Soria pleaded not guilty and stipulated only that she was hired by the private complainant through a manpower service.
- On November 16, 2015, the Regional Trial Court (RTC), Branch 7, Cebu City, convicted Soria of Qualified Arson and sentenced her to reclusion perpetua, temperate damages of ₱500,000 and exemplary damages of ₱50,000 in favor of Mariano P. Parcon, Jr., plus civil indemnity of ₱50,000 and exemplary damages of ₱50,000 in favor of Cornelia’s heirs. On April 30, 2019, the Court of Appeals (CA) affirmed with modification, awarding an additional ₱50,000 as moral damages to Cornelia’s heirs and imposing 6% interest per annum on temperate and exemplary damages from finality.
- Prosecution and Defense Evidence
- Prosecution Witnesses
- Mariano P. Parcon, Jr. testified he awoke to smoke at 2 a.m., his family escaped via a window fire exit, but Cornelia was found dead; the house was razed and damages assessed at ₱2,649,048.72. Soria was missing.
- Eduardo Umandak heard of a woman with a travel bag and gray shoulder bag (later identified as Soria), stopped her climbing the fence at Holy Family Village II, and handed over the black travel bag to Parcon. He identified Soria in a police photo.
- Juanito Octe, common-law partner of Cornelia, testified that the gray shoulder bag and other personal effects recovered from Soria belonged to Cornelia.
- SPO4 Rey Cuyos narrated the hot pursuit arrest in Minglanilla, during which police recovered from Soria a gray shoulder bag containing Cornelia’s items, as well as two Parcon cellphones.
- Ryan Christopher Sorote of TV5 Cebu and The Freeman testified that in a voluntary interview Soria admitted taking employment documents from Parcon’s home office and burning them, unintentionally causing the conflagration and Cornelia’s death, and expressed willingness to face consequences.
- Appellant’s Denial
- Soria claimed that on February 21, 2012 she and Cornelia went out for a snack, but Cornelia failed to return and send her a text message; at around 11 p.m. Soria took a taxi to Talisay City, denying any involvement in setting the fire.
Issues:
- Whether the prosecution proved Soria’s guilt beyond reasonable doubt by circumstantial evidence.
- Whether Soria’s extrajudicial confession to a news reporter is admissible and credible.
- Whether Umandak’s testimony identifying Soria escaping the fire scene is reliable without further corroboration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)