Case Summary (G.R. No. 248372)
Procedural Posture
Appellant pleaded not guilty at arraignment and stipulated at pre-trial only to the fact of her hiring by Parcon through Arizo Manpower Services. The Regional Trial Court (Branch 7, Cebu City) convicted her of Qualified Arson and sentenced her to reclusion perpetua, awarding temperate and exemplary damages and compensation for the victim’s heirs. The Court of Appeals affirmed with modification (added moral damages and interest). The Supreme Court reviewed the appeal and affirmed the conviction as Arson with Homicide, while increasing certain damage awards and ordering interest.
Facts Established by the Prosecution
Prosecution witnesses established that during the early morning of February 22, 2012, Parcon and family were roused by smoke and found their house burning; occupants escaped through a bedroom fire exit; Cornelia Tagalog’s burned remains were recovered; appellant was initially missing; neighbor Umandak encountered a woman (later identified as appellant) at about 4:00 a.m. carrying a black travel bag and a gray shoulder bag (the latter later identified as belonging to Cornelia); appellant allegedly jumped over a fence to Holy Family Village II and left behind the travel bag; police later arrested appellant and recovered from her a gray shoulder bag containing personal effects of Cornelia and two cellular phones that Parcon identified as his; a TV reporter (Sorote) testified that appellant admitted during an interview that she burned employment documents in Parcon’s home office and was willing to accept the consequences.
Appellant’s Account and Defense
Appellant denied committing arson. She claimed she left the Parcon household on the night of February 21, 2012, with Cornelia’s assistance because she wanted to go home to sick children; she asserted Cornelia was to return to collect appellant’s belongings and send a text message which never came; appellant contended she went to Talisay City by taxi and offered an alternative explanation for her absence from the burning scene.
Trial Court’s Findings and Rationale
The RTC found guilt beyond reasonable doubt based on circumstantial evidence and appellant’s purported admission. The court emphasized (1) the undisputed fact of the house burning and Cornelia’s death; (2) the extrajudicial admission to reporter Sorote that she burned employment papers; and (3) Umandak’s testimony identifying appellant as the person he encountered shortly after the fire, carrying items later identified as belonging to the victim. The RTC concluded the burning was deliberate and malicious and imposed reclusion perpetua with awards for temperate and exemplary damages and compensation for Cornelia’s heirs.
Court of Appeals’ Ruling and Modifications
The Court of Appeals affirmed the RTC’s conviction, finding that the circumstantial evidence formed an unbroken chain pointing to appellant as perpetrator. The CA gave weight to the appellant’s voluntary interview statements to the reporter and to the recovery of the victim’s and complainant’s belongings from appellant. The appellate court modified damages by awarding moral damages to the heirs of Cornelia and ordered six percent interest per annum on temperate and exemplary damages from finality of decision to full payment.
Supreme Court’s Issues on Review
The Supreme Court reviewed whether the prosecution proved guilt beyond reasonable doubt through circumstantial evidence and whether appellant’s admission to the reporter was admissible, given her detention and claims of coercion. The Court also considered appropriate penalties and the quantum of damages.
Legal Standard on Circumstantial Evidence Applied
The Court reiterated that circumstantial evidence is permissible and can prove guilt beyond reasonable doubt if three requisites are satisfied: (1) multiple circumstances are present; (2) the foundational facts are proven; and (3) the combined circumstances produce conviction beyond reasonable doubt. The circumstances must be consistent with guilt and inconsistent with any other reasonable hypothesis. The Court cited precedent recognizing that circumstantial evidence may sustain convictions for arson when forming an unbroken chain pointing to the accused.
Application of the Standard to the Record
Applying the threefold test, the Supreme Court found the prosecution established an unbroken chain: the timing and nature of the fire, appellant’s presence at or near the scene before and after the incident, recovery from appellant of personal effects and cellular phones identified by Parcon and by Cornelia’s common-law partner as belonging to the victim, Umandak’s identification of appellant soon after the fire, and appellant’s own statements to the reporter describing burning employment papers in the home office which led to the conflagration. These combined facts were held consistent with appellant’s guilt and inconsistent with innocence or other rational hypotheses.
Admissibility of Extrajudicial Admission to Reporter
The Supreme Court held appellant’s admission to the news reporter admissible. It relied on jurisprudence that being interviewed while in a detenti
...continue readingCase Syllabus (G.R. No. 248372)
Procedural Posture
- Appeal to the Supreme Court from the Court of Appeals (CA) Decision promulgated April 30, 2019, which affirmed with modification the Regional Trial Court (RTC), Branch 7, Cebu City Decision dated November 16, 2015, in Criminal Case No. CBU-95100.
- RTC convicted appellant Aubrey Enriquez Soria of Qualified Arson under Section 1 in relation to Section 5 of P.D. No. 1613. Appellant was sentenced to reclusion perpetua and ordered to pay damages.
- CA affirmed the conviction but modified the award by ordering indemnification of Cornelia Tagalog’s heirs in the amount of P50,000.00 as moral damages and imposed interest at six percent (6%) per annum on temperate and exemplary damages from finality until fully paid.
- The Supreme Court received the appeal raising whether the prosecution established appellant’s guilt beyond reasonable doubt and whether appellant’s extrajudicial admission to a news reporter was admissible and credible.
Title, Case Details and Citations
- Case: People of the Philippines v. Aubrey Enriquez Soria.
- G.R. No.: 248372 (Decision referenced August 27, 2020; reported 880 Phil. 387; 118 OG No. 40, 11082 (October 3, 2022) — First Division).
- RTC Criminal Case No.: CBU-95100.
- Information dated: February 27, 2012.
- Incident date/time: On or about February 22, 2012, at about 2:06 a.m., in Cebu City, Holy Family Village, Barangay Banilad.
- Statute charged: Qualified Arson as defined and penalized under Section 1, in relation to Section 5, of Presidential Decree No. 1613 (the New Arson Law).
Information / Charge Alleged
- Accused-appellant was charged with, with deliberate intent, setting fire to an inhabited house owned and occupied by Mariano Perez Parcon, Jr. and family, located at Holy Family Village, Barangay Banilad, Cebu City, causing the house and its contents to be burned and resulting in the burning to death of Cornelia O. Tagalog, a house helper of Parcon, Jr.
Plea, Pre-trial and Stipulations
- During arraignment, appellant pleaded not guilty to the charge.
- During pre-trial, appellant stipulated to the fact that she had been hired by private complainant Mariano Parcon, Jr., and that the hiring was done through Arizo Manpower Services.
Prosecution Witnesses and Core Factual Narrative
- Prosecution witnesses included Mariano Parcon, Eduardo Umandak, Juanito Octe, Erlyn Arizo, SPO4 Rey Cuyos, Guamittos Logrono, and Ryan Christopher Sorote (TV5 Cebu / The Freeman News reporter).
- Mariano Parcon’s testimony:
- Around 2:00 a.m. on February 22, 2012 he was awakened by the smell of smoke; upon opening his room door he was met by heat and smoke.
- He awakened his wife and children who escaped via the bedroom window fire exit (onto garage roof).
- He called out to Cornelia Tagalog (house helper) but received no reply.
- Occupants of the first floor were alerted by a village security guard and escaped.
- Firemen responded but the house was totally burned, causing calculated damage of P2,649,048.72.
- Firemen recovered the dead body of Cornelia Tagalog; later they noticed appellant was missing.
- Eduardo Umandak’s testimony:
- At about 4:00 a.m., his live-in partner woke him to report a girl asking for help.
- Umandak found a woman (later identified as appellant) sitting on a step of a multi-cab carrying a black travel bag and a gray shoulder bag.
- The woman said she came from Day-as, Cebu, had taken a taxi and disembarked near Parcon’s house, and that her mother asked her to go to Holy Family Village II.
- Appellant asked Umandak’s son to carry the bag and accompany her; Umandak grew suspicious, took the bag and told his son to go home.
- Appellant climbed and jumped over the fence to Holy Family Village II leaving the black travel bag behind.
- At about 5:00 a.m., Umandak learned of the burned house and of a missing helper; he related his encounter with the woman to Parcon.
- Umandak later identified appellant from a photograph shown by the police.
- Identification and recovered items:
- Police arrested appellant and brought her before Parcon for identification; items recovered from appellant included a gray shoulder bag, a pouch, a wallet, ladies' personal effects and two cellular phones.
- Parcon identified the two cellular phones as his and the shoulder bag as belonging to Cornelia Tagalog.
- Juanito Octe (Cornelia’s common-law partner) testified that the gray shoulder bag and other personal effects (transparent pouch, red wallet, perfume, coin purse with keys, handkerchief, lipstick) belonged to Cornelia.
- SPO4 Rey Cuyos testified investigators received the black travel bag from Umandak, identified as appellant’s, and that information pointed to appellant as the suspect since she was the only one who managed to pack belongings and escape the fire.
- Police proceeded to Dumlog, Talisay City and found appellant at her uncle’s house in Minglanilla; upon spotting police she ran and hid in a nearby house where she was arrested.
- From appellant the police recovered a gray shoulder bag containing a red wallet, a coin purse, a perfume, five cellphones, a lipstick and a match.
- Ryan Christopher Sorote’s testimony:
- Covered the fire incident for TV5 Cebu and The Freeman News.
- Interviewed appellant after arrest; testified that during the interview appellant admitted to the crime and supplied details on how and why she burned documents which led to the conflagration.
Appellant’s Defense / Version
- Appellant denied committing the offense.
- Version presented:
- On the morning of February 21, 2012 she wished to go home because her children were sick; Parcon refused permission.
- She escaped at about 9:00 or 10:00 p.m. on February 21, 2012 with Cornelia’s assistance.
- They told Parcon they were going out for a snack; Cornelia would later return, fetch appellant’s things and send her a text message.
- At 11:00 p.m. appellant had not received the promised text message and proceeded to Talisay City by taxi.
Trial Court (RTC) Decision — Findings and Sentence (Nov. 16, 2015)
- RTC found appellant guilty beyond reasonable doubt of Qualified Arson under P.D. No. 1613.
- RTC’s dispositive sentence:
- Appellant Aubrey Enriquez Soria sentenced to suffer the penalty of reclusion perpetua, including all accessory penalties.
- Ordered to pay Marciano P. Parcon, Jr.: temperate damages of P500,000.00 and exemplary damages of P50,000.00.
- Ordered to pay the heirs of Cornelia Tagalog: compensation for death P50,000.00 and exemplary damages of P50,000.00.
- RTC’s reasoning supporting conviction:
- No dispute the house was razed by fire on February 22, 2012.
- Appellant made an admission to Sorote (news reporter) which Sorote testified to.
- Umandak testified he saw appellant escaping the village and appellant admitted she escaped (albeit giving a different reason).
- Appellant’s narration that she torched employment documents and escaped, instead of alerting occupants, constituted circumstantial evidence of deliberate and malicious burning.
Court of Appeals (CA) Decision — Findings and Modification (Apr. 30, 2019)
- CA denied appellant’s appeal and affirmed RTC’s decision with modification.
- CA modified awards by ordering appellant to indemnify the heirs of Cornelia Tagalog P50,000.00 as moral damages (in addition to damages already awarded by RTC).
- CA imposed interest at six percent (6%) per annum from finality of decision until fully paid on temperate and exemplary damages awarded by the court.
- CA affirmed conviction largely on circumstantial evidence: circumstances pointed to appellant as the author of the crime.
- CA addressed appellant’s contention regarding the voluntariness and intelligence of her admission to Sorote, concluding appellant voluntarily agreed to inte