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PEOPLE v. ALAMADA MACABANDO

FACTS:

Appellant Alamada Macabando was charged with the crime of destructive arson after allegedly intentionally setting his house on fire. The prosecution presented evidence showing that the appellant broke bottles on the road, shouted that he wanted to get even, and uttered that he would burn his house. Later that day, smoke was seen coming from the appellant's house, and neighbors attempted to extinguish the fire. The appellant, carrying a traveling bag and a gun, warned people not to interfere and fired three shots in the air. Fire officers conducted an investigation and determined that the fire was intentional. The defense presented a different version of events, with the appellant claiming that he was asleep when the fire started and denied making any threats or owning a gun. The trial court found the appellant guilty beyond reasonable doubt of destructive arson, and the CA affirmed the judgment.

ISSUES:

  1. Whether the appellant, Alamada Macabando, is guilty beyond reasonable doubt of destructive arson under Article 320 of the Revised Penal Code.

RULING:

  1. No, the appellant is not guilty of destructive arson. The Supreme Court found that the appropriate classification was simple arson under Section 3(2) of Presidential Decree No. 1613, given that the evidence showed the appellant intentionally burned his own house, which subsequently caused the fire to spread to neighboring houses.

PRINCIPLES:

  • Circumstantial Evidence In the absence of direct evidence, circumstantial evidence can be sufficient for conviction if it creates a moral certainty excluding all other hypotheses except that of guilt.

  • Destructive Arson (Article 320, RPC) Characterized by a higher degree of perversity and viciousness, and often involving public and significant structures.

  • Simple Arson (Section 3, P.D. No. 1613) Involves the burning of less significant structures with a lower degree of perversity, and punished with a lesser penalty.

  • Indeterminate Sentence Law Imposes an indeterminate penalty wherein the minimum term is taken from the penalty next lower in degree, and the maximum from the specific range of the penalty for the crime charged.