G.R. No. 188708 - People vs. Macabando

Case Summary (G.R. No. 188708)

Charges and Procedural History

Alamada Macabando was charged with destructive arson under Article 320 of the Revised Penal Code (RPC), as amended, before the RTC. He pleaded not guilty. The RTC, in a judgment dated August 26, 2002, found Macabando guilty beyond reasonable doubt and sentenced him to reclusion perpetua. This decision was affirmed in toto by the Court of Appeals on February 24, 2009, prompting the appellant to file an appeal before the Supreme Court.

Summary of the Incident and Prosecution’s Evidence

On December 21, 2001, around 4:00 p.m., the appellant was observed acting violently near his house while holding a G.I. pipe and breaking bottles, uttering threats to get even and to burn his house. Two hours later, neighbors observed fire and smoke coming from his house. Despite efforts by neighbors to extinguish the fire, the appellant prevented them, brandishing a gun and firing shots to intimidate them. Fire officers conducted a spot investigation and concluded the fire was intentional and originated from the appellant's house. Barangay officials and Social Welfare personnel confirmed extensive damage affecting several residential houses.

Defense’s Version of Events

The appellant denied ownership of a gun, claimed he was asleep when the fire started, denied issuing threats to burn his house, and explained the gunshots heard by neighbors as firecrackers intended for New Year celebrations. Family members supported his claim that he was asleep and did not fire shots or act with hostility on that day.

Legal Basis for Relying on Circumstantial Evidence

Because no one directly witnessed the appellant setting the fire, the courts utilized circumstantial evidence. The Supreme Court reaffirmed the well-established rule that conviction based on circumstantial evidence requires (a) more than one circumstance; (b) each fact proven; and (c) the circumstances combined must exclude all others and lead to moral certainty of guilt. Applying this standard, the Court determined an unbroken chain of events strongly indicated the appellant’s guilt.

The Unbroken Chain of Circumstances Establishing Guilt

The Court highlighted multiple converging facts: the appellant's violent behavior and threats prior to the fire; the fire originating in his house; his obstruction of fire extinguishing attempts coupled with threats to kill; the use and firing of a gun during the fire; and his possession of a traveling bag indicating preparedness to flee. These collectively contradicted his claims of innocence and passive behavior.

Nature of the Crime: Destructive Arson vs. Simple Arson

While the CA convicted the appellant under Article 320 (destructive arson), the Supreme Court found that the evidence supported only simple arson under Section 3(2) of Presidential Decree No. 1613 (P.D. 1613), which punishes the malicious burning of an inhabited house or dwelling not covered by the more severe Article 320. Destructive arson targets more significant structures and involves acts with greater social and economic consequences, whereas simple arson involves less grave offenses.

Elements of Simple Arson Proven

The requisites of simple arson—(a) intentional burning and (b) burning an inhabited dwelling—were clearly established through testimonial evidence, fire marshal reports, and official certifications. Although the fire spread to neighboring houses, the evidence showed that the appellant only intended to burn his own inhabited house, and thus the crime corresponds to simple arson.

Appropriate Penalty and Application of the Indeterminate Sentence Law

Simple arson under P.D. No. 1613 carries a penalty ranging from reclusion temporal to reclusion perpetua. Applying the Indeter

Case Syllabus (G.R. No. 188708)

Facts of the Case

On December 21, 2001, at around 4:00 p.m., appellant Alamada Macabando was seen breaking bottles on the road while holding a G.I. pipe and shouting a threat to "get even."
The appellant additionally declared that he would burn his house.
At approximately 6:35 p.m. the same day, neighbors alerted Cornelio Feliciano about a fire at the appellant’s house.
Cornelio tried to put out the fire with water.
Eric Quilantang, a nearby neighbor, fetched a fire extinguisher and attempted to approach the burning house but was rebuffed by the appellant.
The appellant was carrying a traveling bag and a gun and fired three shots in the air to deter interference.
The appellant threatened anyone who would attempt to put out the fire with death.
Consequently, neighbors retreated to protect their loved ones and belongings.
Bureau of Fire Protection officers concluded the fire originated intentionally from the appellant’s house.
Barangay Chairman Modesto Ligtas confirmed that multiple houses were gutted and assisted in damage assessment.

Defense and Contradictory Testimonies

The appellant claimed ownership of the burnt two-story house, which was owned by his sister but denied any involvement in the arson.
He admitted feeling angry earlier that day due to a stolen radio cassette but asserted he slept afterwards and the fire was already ongoing upon waking.
The appellant denied threatening to burn his house or owning a gun, attributing gunshots to firecrackers planned for New Year celebrations.
His cousin and brother-in-law corroborated seeing him asleep or absent of violent conduct during the incident.
The appellant maintained he bore no prior grudges with witnesses, contradicting the prosecution’s narrative.

Procedural History

The prosecution charged Alamada Macabando with destructive arson under Article 320 of the Revised Penal Code (RPC), as amended, before the Regional Trial Court (RTC).
On August 26, 2002, the RTC found appellant guilty beyond reasonable doubt and sentenced him to reclusion perpetua.
The Court of Appeals (CA), in CA-G.R. CR HC No. 00208-MIN, affirmed the RTC decision on February 24, 2009.
The appellant filed an appeal challenging these rulings.

Issues Presented

Whether the prosecution sufficiently proved the guilt of the appellant beyond reasonable doubt.
Whether the crime committed is destructive arson as charged or simple arson.
The proper penalty to be imposed considering the factual circumstances and applicable law.
The propriety of awarding damages to the offended parties.

Legal Principles on Circumstantial Evidence

Conviction can be based on circumstantial evidence where:
- More than one circumstance exists.
- The facts from which inferences are drawn are proven.
- The combination of circumstances re