FACTS:

The case involves the conviction of the petitioner for arson. The Regional Trial Court (RTC) in Cebu City sentenced the petitioner to a period of ten years of Prision Mayor in its medium period as a minimum and sixteen years of Reclusion Temporal in its medium period as a maximum. The Court of Appeals (CA) affirmed the conviction. The petitioner appealed to the Supreme Court, arguing that there was a lack of direct evidence against him and that the circumstantial evidence presented was insufficient to support his conviction beyond reasonable doubt.

The State's witnesses testified that they heard petitioner demanding money from his sister, then saw a commotion inside the house, and witnessed the petitioner waving a flaming blanket that he had lit from the stove. The witnesses also saw the petitioner coming out of the house and daring anyone to arrest him. The fire subsequently spread and burned down the house.

The CA held that the State's circumstantial evidence was sufficient to convict the petitioner, as an unbroken chain of circumstances pointed to his guilt.

However, the Supreme Court found that the penalty imposed by the RTC and affirmed by the CA was legally erroneous. The information specifically alleged that the property burned was an inhabited dwelling, which carries the penalty of reclusion temporal to reclusion perpetua. The penalty should have been divided into three equal portions of time, with reclusion perpetua serving as the maximum penalty.

ISSUES:

1. Did the RTC and CA err in their appreciation of the evidence?

2. Was there sufficient evidence to establish the guilt of the petitioner beyond reasonable doubt?

RULING:

1. The Court affirms the conviction.

2. The lack or absence of direct evidence does not necessarily mean that the guilt of the accused cannot be proved by circumstantial evidence. Circumstantial evidence, if sufficient, can support a conviction beyond reasonable doubt. In this case, the State's witnesses provided a chain of circumstances that incriminated the petitioner in the arson. The unbroken chain of events and the credibility of the witnesses warrant the conclusion that the petitioner deliberately caused the burning of the house.

PRINCIPLES:

• Circumstantial evidence can supplant the absence of direct evidence and support a conviction beyond reasonable doubt.

• The trier of fact must be convinced beyond a reasonable doubt of the guilt of the accused, whether using direct evidence or circumstantial evidence.

• For circumstantial evidence to warrant a conviction, there must be more than one circumstance, the facts from which the circumstances arose must be duly established in court, and the circumstances must form an unbroken chain of events leading to the fair conclusion of the culpability of the accused.

• The penalty prescribed for the crime must be in accordance with the law and the specific circumstances of the case.