CRIM2: Gonzales VS People of the Philippines

GONZALES VS PEOPLE OF THE PHILIPPINES
GR 159950
February 12, 2007

FACTS:
For review on certiorari is the Decision dated March 11, 2003 of the Court of Appeals in CA-G.R. CR No. 22157, affirming the guilty verdict against petitioner for arson by the Regional Trial Court (RTC) of Quezon City, Branch 97.
Petitioner Joel P. Gonzales, Jr. was charged in an Information dated July 24, 1997, which read as follows: That on or about the 26th day of June, 1997, in Quezon City, Philippines, the said accused, did then and there wilfully, unlawfully, feloniously and deliberately set fire to an inhabited place, to wit: a two-storey residential building which [was] partitioned into dwellings rented out to tenants, thereby setting said residential building into flames and razing it including other properties.
On arraignment, the petitioner pleaded not guilty.
Carlos C. Canlas testified on his way to the room rented by Gonzales, he smelled gas. He saw Gonzales ignite a flame and throw it on a pile of clothes in the middle of the living room where Gonzales had also placed an M-Gas liquefied petroleum gas (LPG) tank. Fire quickly spread to the other parts of the building.
On May 28, 1998, the RTC of Quezon City, Branch 97 rendered a decision convicting Joel P. Gonzales, Jr. of arson. Gonzales appealed, but the Court of Appeals affirmed the trial court’s decision

ISSUE: WHETHER UPON THE AFORESTATED GIVEN SET OF FACTS, THE HONORABLE COURT OF APPEALS ACTED CORRECTLY IN AFFIRMING THE TRIAL COURT’S JUDGMENT OF CONVICTION FINDING PETITIONER GUILTY OF THE CHARGE OF ARSON

HELD/RATIO DECIDENDI:
Tthe Decision of the Court of Appeals sustaining the conviction by the RTC finding the accused-petitioner guilty of the crime of arson of an inhabited dwelling is AFFIRMED
The arson committed in the instant case involving an inhabited house or dwelling is covered by Section 3(2) of Presidential Decree No. 1613. In the prosecution for arson, proof of the crime charged is complete where the evidence establishes: (1) the corpus delicti, that is, a fire because of criminal agency; and (2) the identity of the defendant as the one responsible for the crime. In arson, the corpus delicti rule is satisfied by proof of the bare fact of the fire and of it having been intentionally caused. Even the uncorroborated testimony of a single eyewitness, if credible, is enough to prove the corpus delicti and to warrant conviction. When these are present, the only issue is the credibility of the witness. Whenever there is inconsistency between the affidavit and the testimony of a witness in court, the testimony commands greater weight considering that affidavits taken ex parte are inferior to testimony in court, the former being almost invariably incomplete and oftentimes inaccurate, sometimes from partial suggestions and sometimes from want of suggestions and inquiries, without the aid of which the witness may be unable to recall the connected circumstances necessary for his accurate recollection of the subject.