People vs. Soria (G.R. No. 248372, August 27, 2020) (CASE DIGEST)

People vs. Soria (G.R. No. 248372, August 27, 2020)

Facts

Aubrey Enriquez Soria, a house helper, was charged with Qualified Arson for the deliberate setting of fire to the inhabited house of her employer, Mariano Perez Parcon, Jr., resulting in the death of fellow house helper, Cornelia O. Tagalog.

There was no direct eyewitness to the fire’s commencement. However, circumstantial evidence established that Soria was the perpetrator:

1. Soria was caught by a neighbor (Umandak) escaping the village by climbing over a fence shortly after the 2:00 a.m. fire.
2. Upon arrest, police recovered items stolen from the Parcon house (two cellular phones belonging to Parcon) and personal effects (a gray shoulder bag, red wallet, etc.) belonging to the deceased Tagalog.
3. A news reporter (Sorote) interviewed Soria after her arrest, during which Soria admitted that she took items because she needed money and, on her way out, thought of burning her employment documents in Parcon’s home office, which caused the fire to spread and burn the entire house.
4. The trial court (RTC) and the Court of Appeals (CA) found that this chain of events proved Soria’s guilt.

Issues

1. Whether the prosecution established appellant Soria’s guilt beyond reasonable doubt.
2. Whether the circumstantial evidence presented was sufficient to convict Soria.
3. Whether Soria’s admission of guilt made to a news reporter while she was detained was admissible evidence.

Ruling

The Court AFFIRMS the Decision of the Court of Appeals, dated April 30, 2019, in CA-G.R. CEB CR. HC. No. 02503, finding appellant Aubrey Enriquez Soria GUILTY beyond reasonable doubt of the crime of Arson with Homicide.

Essential Elements of Jurisprudence

1. Nature of the Crime: Arson which results in death is penalized under Presidential Decree (P.D.) No. 1613, otherwise known as the New Arson Law. Section 1, in relation to Section 5, imposes the penalty of Reclusion Perpetua to death if the property burned is an inhabited house and death results “by reason of or on the occasion of the arson”. The elements of the crime are: (a) there is intentional burning; and (b) what is intentionally burned is an inhabited house or dwelling.
2. Sufficiency of Circumstantial Evidence: Guilt beyond reasonable doubt can be established through circumstantial evidence; direct evidence is not the sole requirement.
3. Requirements for Conviction via Circumstantial Evidence (Rule 133, Section 5): To sustain a conviction based on circumstantial evidence, three requisites must be established: (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.
4. Chain of Circumstances: The circumstances proven must be consistent with each other, consistent with the hypothesis that the accused is guilty, and simultaneously inconsistent with the hypothesis that the accused is innocent, and with every other rational hypothesis except that of guilt. The circumstances must constitute an unbroken chain leading to the conclusion that the accused is the guilty person.
5. Admissibility of Extrajudicial Admissions to Media: An extrajudicial confession or admission made by an accused to a news reporter is admissible in evidence against her, even if made inside a detention cell, provided that the confession was given freely and spontaneously. Where the reporter acted as a member of the media and not under the direction and control of the police, and the accused voluntarily supplied details regarding the commission of the offense, the admission is valid.

Sample Q&A

Question: Aubrey Soria was convicted of Arson with Homicide (Qualified Arson) for intentionally burning her employer’s inhabited house, resulting in the death of a co-worker. Soria argued on appeal that her conviction was invalid because there was no direct eyewitness and because her admission of burning her employment documents (which caused the conflagration) was made to a television news reporter while she was detained. Did the Supreme Court correctly affirm Soria’s conviction? Cite the relevant legal provisions.

Answer: Yes, the Supreme Court correctly affirmed Soria’s conviction.

The conviction for Arson with Homicide, defined and penalized under Section 1, in relation to Section 5, of P.D. No. 1613 (New Arson Law), was validly based on circumstantial evidence.

While no eyewitness saw the starting of the fire, the Court found that the prosecution established an unbroken chain of circumstances—including Soria’s flight from the scene, her possession of stolen items belonging to the employer and the deceased, and her confession—which satisfied the three requisites for conviction through circumstantial evidence as mandated by Rule 133, Section 5 of the Revised Rules on Evidence.

Furthermore, the admission Soria made to the news reporter was deemed admissible because the interview was not done in the course of a police investigation and the confession was voluntarily given while the reporter was acting as a member of the media. The fact that the admission was made while Soria was detained did not, by itself, render the confession inadmissible.

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