Frances Katherine Miraflor-Antonio

People of the Philippines vs. Murcia, G.R. No. 182460, March 9, 2010, Perez
Facts:
While on a drinking spree, the accused, Murcia, had an argument with
Herminio. Murcia then got a bolo and ran after Herminio but the latter was able to
escape. A few minutes later, a smoke was seen coming from the room of Murcia.
Herminio witnessed him burning some clothes and immediately went inside the
house to save his belongings. Upon emerging from the house, Herminio saw his
mother, Alicia, bloodied because Murcia stabbed her. Murcia also stabbed two
other persons, Felicidad and Alicia, who are both occupants of the burning
house. Eight houses in total were razed.
Murcia was charged with the crime of arson and frustrated homicide. He
admitted to the crime of frustrated homicide but denied setting the house on fire.
He questioned the credibility of some witnesses and specifically imputed illmotive on the part of Herminio in testifying against him, especially after their fight.
He also submitted that the testimonies of the witnesses did not prove the identity
of the perpetrator.
Issue:
Whether or not Murcia is guilty of the crime of arson.
Held:
Yes, Murcia is guilty of the crime of arson. While nobody directly saw him
burn the house, there were enough circumstances which yielded to a logical
conclusion that the fire that gutted eight houses was authored by him.
Murcia imputes ill-motive on the part of Herminio. The Court does not
discount the fact that there was a fight between appellant and Herminio which
preceded the occurrence of the fire. However, it cannot be presumed that
Herminio will automatically give a false testimony against appellant. His
testimony, having withstood cross-examination, has passed the scrutiny of the
lower courts and was held to be credible.

People of the Philippines vs. Malngan, G.R. No. 170470, September 26, 2006,
Chico-Nazario
Facts:
At around 4:45am on January 2, 2001, Remigio Bernardo, the Barangay
Chairman in the area, and his tanods saw the accused, Edna, a housemaid,
leaving the house of her employer, Roberto Separa Sr., with her head turning in
different directions. At around 5:15am, Barangay Chairmans group discovered
that a fire gutted the house of Ednas employer. The fire resulted in the
destruction of the house of Roberto Separa, Sr. and other adjoining houses and
the death of Roberto Separa, Sr. and Virginia Separa together with their four
children.
A disposable lighter was found in the possession of Edna. Thereafter, in
the presence of multitudes of angry residents outside the barangay hall, Edna
confessed that she set her employers house on fire because she had not been
paid her salary for about a year and that she wanted to go home to her province
but her employer told her to just ride a broomstick in going home.
Edna contends the following: (a) The prosecutions evidence to assert her
guilt beyond reasonable is insufficient since the prosecution was only able to
adduce to circumstancial evidence. (b) Her uncounselled extrajudicial confession
is not admissible as evidence against her for being violative of Article III, Section
12(1) of the Constitution. (c) Since the identities of the burned bodies were never
conclusively established , she cannot be responsible for their deaths.
Issue:
Whether or not Edna is guilty of the crime of arson.
Held:
Edna is guilty of the crime of simple arson.
In this case, the interlocking testimonies of the prosecution witnesses,
taken together, exemplify a case where conviction can be upheld on the basis of
circumstantial evidence. While the prosecution witnesses did not see
accused-appellant actually starting the fire that burned several
houses and killed the Separa family, her guilt may still be
established through circumstantial evidence provided that: (1) there
is more than one circumstance; (2) the facts from which the
inferences are derived are proven; and, (3) the combination of all
the circumstances is such as to produce conviction beyond
reasonable doubt.

To be admissible in evidence against an accused, the extrajudicial

confessions made must satisfy the following requirements:
1. it must be voluntary;
2. it must be made with the assistance of competent and independent
counsel;
3. it must be express; and
4. it must be in writing.
Arguably, the barangay tanods, including the Barangay Chairman, in this
particular instance, may be deemed as law enforcement officer for purposes of
applying Article III, Section 12(1) and (3), of the Constitution.
In the crime of arson, the identities of the victims are immaterial in that
intent to kill them particularly is not one of the elements of the crime. As we have
clarified earlier, the killing of a person is absorbed in the charge of arson, simple
or destructive. The prosecution need only prove, that the burning was intentional
and that what was intentionally burned is an inhabited house or dwelling.

People of the Philippines vs. Oliva, G.R. No. 122110, September 26, 2000,
Pardo
Facts:
On August 23, 1993, at around eleven o'clock in the evening, Avelino Manguba
and his family were sleeping in their house in San Jose, Claveria, Cagayan.
Avelino went out of the house to urinate. He saw Ferigel Oliva set the roof of their
house on fire with a lighted match. Awakened by the loud barking of dogs,
Avelino's wife sensed danger and peeped through a hole in their wall. She also
saw Ferigel burn the roof of their house. She shouted, "Perry is burning our
house!" and called out to the neighbors for help. While the fire razed Avelino's
house, Ferigel and three others, Dominador Oliva, Marcos Paderan and Arnel
Domingo watched at a distance of about five (5) meters.
One of the neighbors, Benjamin Estrellon went to the nearby river and
fetched water with a pail. As Benjamin was helping put out the fire, he was shot
by Ferigel at close range. Benjamin tried to run, but he slumped and fell to the
ground. The gunshot wound caused Benjamin's death. Avelino, his wife, and
Benjamin's son, Noel, witnessed the shooting.
A crime of murder and arson where charged against Ferigel Oliva,
Dominador Oliva, Marcos Paderan, and Arnel Domingo. Oliva escaped while in
custody of P/G-1 Joaquin P. Garingan. At the time of his escape, Ferigel was a
detention prisoner at the Provincial Jail Extension of Sanchez Mira, Cagayan.
Thereafter, Ferigel was apprehended at Angadanan, Isabela by prison guards
Joaquin P. Garingan and Angelino M. Cacatian, members of the Scout Ranger
regiment and members of the PNP of Angadanan, Isabela. The cases for arson
and murder were tried jointly. In view of the common evidence presented coupled
with the difficulty of distinguishing which evidence was for a particular case, only
one decision was rendered.
Marcos Paderan, Arnel Domingo and Dominador Oliva were acquitted of
the crime of Arson and Murder for lack of evidence. Ferigel Oliva was found guilty
beyond reasonable doubt for both the crimes of arson and murder.
For the crime of arson, Ferigel argues that the trial court erred when it took
into account the qualifying circumstance of treachery in the commission of
murder and the fact that the house was inhabited when it was burned.

Issues:
Whether or not Oliva is guilty of the crime of Arson.
Held:
When Ferigel burned Avelino's house, the law applicable was P. D. No.
1613. Under Section 3 (2) of the law, the penalty of reclusion
temporal to reclusion perpetua shall be imposed if the property burned is "any
inhabited house or dwelling." Under the amendment, it is the fact that the house
burned is inhabited that qualifies the crime. There is no need to prove that the
accused had actual knowledge that the house was inhabited.
Under Section 3 (2) of Presidential Decree No. 1613, the elements of
arson are: (1) that there is intentional burning; and (2) that what is intentionally
burned is an inhabited house or dwelling. The records show that when Ferigel
willfully set fire to the roof of Avelino's house, Avelino's wife and children were
asleep therein.
In arson, the corpus delicti rule is satisfied by proof of the bare occurrence of the
fire and of its having been intentionally caused. The uncorroborated testimony of
a single eyewitness, if credible, may be enough to prove the corpus delicti and to
warrant conviction. Here, corpus delicti of the arson and murder was duly proven
beyond reasonable doubt.