G.R. No. 7540 - People vs Mendoza

On the evening of August 1, 1910, at about 8 o’clock, Bernabe Mangunay, mounted on a carabao and carrying a papaya firebrand, approached the house of Mateo del Rosario in the barrio of Apulid, Paniqui, Tarlac.
The firebrand came too close to the house, causing the eaves to catch fire, which consequently set the nipa roof ablaze.
Silveria Marcoleta, the wife of the house owner, alerted by the sudden fire and while not being present in the house, called for help and immediately left along with her two children and little brother to escape.
The prompt arrival of the owner, Mateo del Rosario, together with several neighbors, ensured that the blaze was contained before the entire house was consumed.

The following day, Mateo del Rosario reported the incident to Vicente Mendoza, the barrio lieutenant of Apulid, accusing Bernabe Mangunay of deliberately starting the fire.
Mendoza issued the order through junior lieutenant Candido Yabut to summon Mangunay, but despite the summons and the accused’s appearance, Mendoza took no direct action.
Instead of prosecuting, Mendoza allowed the accused to return home without reporting the facts to the proper higher authority.

Subsequent investigations by the justice of the peace in Paniqui, along with preliminary inquiries by the provincial fiscal, led to an information being filed before the Court of First Instance of Tarlac on September 5, 1910.
Vicente Mendoza was charged as an accessory after the fact in the crime of arson under the information for concealment of crime.
Simultaneously, in an associated case (Case No. 544), Bernabe Mangunay, the alleged incendiary, was prosecuted and eventually acquitted for lack of evidence.
After trial, on May 22, 1911, Mendoza was convicted and sentenced to two years, four months, and one day of presidio correccional, with the accessory’s sentence computed at half of the total detention period, plus the payment of costs.

Had Mendoza’s conduct warranted criminal responsibility, his actions could have constituted “prevaricacion” under Article 355 of the Penal Code, due to neglect in performing his official duties by maliciously failing to pursue the case.
However, the case was prosecuted via an information for concealment of crime, not under the specific offense of prevarication.

Whether the conviction of Vicente Mendoza as an accessory after the fact is tenable when the principal actor, Bernabe Mangunay, had already been acquitted for lack of evidence of the crime of arson.
Whether the doctrines of accessory liability, which require the existence and commission of a bona fide principal crime, can be applied when the underlying criminal act itself is debatable or possibly accidental.
If the absence of proven criminal intent or actual commission of arson by the principal implicates the inappropriateness of holding Mendoza criminally responsible, despite his alleged neglect of duty.