Case Summary (G.R. No. 185209)
Petitioner
The People of the Philippines, represented by the public prosecutor.
Respondent
Mae Al-Saad y Bagkat, accused of Arson with Homicide under PD 1613.
Key Dates
– September 14, 2010: Alleged commission of the crime.
– October 21, 2010: Arraignment; plea of not guilty.
– April 29, 2015: RTC Branch 199, Las Piñas City decision convicting respondent.
– May 4, 2018: Court of Appeals decision affirming conviction with modified damages.
– March 15, 2021: Supreme Court resolution of the appeal.
Applicable Law
Presidential Decree No. 1613 (New Arson Law, as amended) defining and penalizing arson and prescribing Reclusion Perpetua where death results. The 1987 Constitution governs the decision.
Facts of the Case
In the early hours of September 14, 2010, respondent purchased over four liters of gasoline from Optimus Shell Gasoline Station, accompanied by her toddler. Neighbors and family witnesses recounted respondent’s unusual errands—sending househelp for supplies, riding a tricycle that later bore a gasoline odor, and loitering at the guardhouse prior to the fire. Grace returned to find the house ablaze; Ameerah and Ibrahim perished, and Sarah suffered serious burns. Forensic and fire-protection experts found no electrical short circuit but noted indicators of accelerant use.
Procedural History
Respondent was charged by Information with Arson causing death and injury. After a trial at RTC Branch 199, she was convicted and sentenced to Reclusion Perpetua with civil indemnity awards. The Court of Appeals affirmed the conviction, added exemplary damages, and imposed six-percent interest on all damages. Respondent appealed to the Supreme Court.
Issue
Whether respondent’s guilt of Arson with Homicide was proven beyond reasonable doubt.
Decision of the Supreme Court
Guilt was affirmed. The Court held that the prosecution established intentional burning of an inhabited dwelling resulting in two deaths, satisfying the elements of PD 1613’s Section 3(2) and Section 5. Circumstantial evidence formed an unbroken chain pointing exclusively to respondent.
Legal Reasoning
- Arson requires (a) intentional burning and (b) that the property be an inhabited house.
- Death resulting from arson elevates the penalty to Reclusion Perpetua under Section 5.
- Circumstantial evidence, sanctioned by Rule 133(4), need only form a consistent, unbroken chain excluding every reasonable hypothesis of innocence.
- Purchases of gasoline, m
Case Syllabus (G.R. No. 185209)
Procedural History
- Accused-appellant Mae Al-Saad y Bagkat was charged by Information on September 20, 2010 with Arson with Homicide under PD 1613 for setting fire to an inhabited house in Las Piñas City, resulting in two deaths and one serious injury.
- She pleaded not guilty at her arraignment on October 21, 2010, and trial commenced.
- The Regional Trial Court (Branch 199, Las Piñas City) rendered its Decision on April 29, 2015, finding her guilty beyond reasonable doubt, imposing reclusion perpetua, and ordering indemnities.
- The Court of Appeals, in CA G.R. CR-HC No. 07502, affirmed the RTC decision on May 4, 2018, with modifications to the awards for civil indemnity, exemplary damages, and interest.
- This appeal under Rule 45 seeks relief from the Supreme Court, challenging the sufficiency of evidence to convict her of Arson with Homicide.
Facts of the Case
- On September 14, 2010, at approximately 1:00 AM, a fire broke out at the Al-Saad residence in BF Resort Village, Las Piñas City.
- Two stepchildren, Ameerah (14) and Ibrahim (12), perished in the blaze; Sarah (16) sustained serious burns.
- The house helper, Grace Daligdig, and the eldest son, Abdul, testified about waking, seeing flames, and escaping through a locked door.
- Neighbors and barangay officials observed Mae Al-Saad y Bagkat and her youngest child near the burning house and noted suspicious behavior.
- A gasoline attendant and the station manager produced CCTV footage and receipts showing Mae bought 4.189 liters of gasoline at around 3:00 AM near the time of the fire.
Version of the Prosecution
- Mae returned to her home around 1:20 AM after an outing, instructed Grace to fetch milk, and was later seen purchasing gasoline at 2:59 AM.
- Tricycle driver Lemuel Tudio smelled gasoline in the vehicle after Mae disembarked.
- Barangay Tanod Roily Morallos saw Mae return to the village, hiding something while offering him juice and cigarettes, claiming an electrical spark in the kitchen.
- Fire investigators noted spalling on concrete walls, absence of damage to the wiring Mae reported, and collected debris evidencing use of an accelerant.
- Forensic chemist Rosales found no residual flammable substance—attributed to firefighting operations—yet opined a flammable substance likely caused the fire.