Case Digest

Facts:
The case involves Wilson Cacho y Songco (accused-appellant) who was charged with the
crimes of Murder and Destructive Arson. The accused-appellant was accused of killing
Mario Balbao and burning his house in the Municipality of Rodriguez, Province of Rizal,
Philippines. The accused-appellant pleaded not guilty to the charges and trial ensued.
The trial court found the accused-appellant guilty of the crimes charged and sentenced
him to Reclusion Perpetua for Murder and Destructive Arson. The accused-appellant
appealed the decision to the Court of Appeals (CA), which affirmed the trial court's
decision.

Issue:
The main issues to be resolved in this case are: 1) whether the accused-appellant
sufficiently proved his defense of insanity; and 2) whether the crimes of Murder and
Destructive Arson were sufficiently proved.

Ruling:
After a careful review of the records, the Court held that the accused-appellant failed to
sufficiently prove his defense of insanity. The Court also found that the prosecution
failed to prove the existence of the qualifying circumstances of treachery, evident
premeditation, and nighttime, which would qualify the crime to murder. Therefore, the
accused-appellant can only be convicted of the crime of Homicide. The Court also found
that the accused-appellant is liable for a separate crime of Destructive Arson, as the
burning of the victim's house was done to hide or conceal the commission of the crime.
The Court affirmed the decision of the CA, but modified the penalties and damages
imposed on the accused-appellant.

Ratio:
To successfully invoke the defense of insanity, the accused must prove that he was
completely deprived of intelligence at the time or immediately before the commission of
the offense. In this case, the accused-appellant failed to prove that he was insane at the
time of the commission of the crime.

The prosecution has the burden of proving the existence of the qualifying circumstances
alleged in the Information. In this case, the prosecution failed to prove the existence of
the qualifying circumstances of treachery, evident premeditation, and nighttime, which
would qualify the crime to murder.

If the main objective of the accused is to burn a building or edifice, but death results by
reason or on the occasion of arson, the crime is simply arson, and the resulting homicide
is absorbed. If the main objective is to kill a particular person and fire is used as a means
to accomplish that goal, the crime committed is murder only. If the objective is to kill a
particular person and fire is used to cover up the killing, then there are two separate and
distinct crimes committed - homicide/murder and arson.