People v. Mananquil (1984) Digest

People v. Mananquil 1984  Prosecution’s version: o At 11 PM of March 6, 1965, defendant Valentina Mananquil bought 10 cents worth of gasoline from Esso gasoline station, put it in a coffee bottle, and went to her husband, Elias Day y Pablo’s, guard post at NAWASA. o Valentina was angry because he burned her clothing, had a mistress, and had taken all the food from their house. o Elias shouted at her, cursing her, so Valentina took the bottle and poured its contents on the victim’s face. She then took a matchbox and set his polo shirt on fire. o Afterwards, she admitted burning the victim to the Pasay City Police. o Elias was taken to the hospital, then he died on March 10, 1965 due to pneumonia, a complication caused by the burns.  Valentina’s version: o She was out beause she remembered that it was a Sunday the next day and that she had to go to Church, but her shoes were still dirty, so she bought gasoline to clean them. She remembered her husband needed gasoline for his lighter, so he dropped by his workplace. o When she saw Elias, he was drunk and started cursing at her. She became dizzy and did not know that she was sprinkling gasoline on his face. o She remembered her grandson whom she left at home, so she left her husband there. She could not sleep later on, so she went back to NAWASA to apologize, but instead found police officers. Elias was there and still angry; he chased her. o A police officer asked if she was his wife and accused her of burning Elias, which she denied. o She was taken to headquarters where there was already a written statement for her to sign.  Right after the burning incident, the Pasay City Police picked up Valentina and interrogated her. She categorically admitted having thrown gasoline at her husband and thereafter set him aflame in her extrajudicial confession.  The Court of First Instance, Rizal found Valentina guilty, sentencing her to reclusion perpetua. She appealed to the Court of Appeals, which referred her case to the Supreme Court due to the penalty imposed 1. WoN Valentina Mananquil is criminally liable for her partner’s death  YES. Art, 4, Par. 1 of the Revised Penal Code provides, “Criminal liability shall be incurred. 1. By any person committing a felony (delito) although the wrongful act done be different from that which he intended,” the essential requisites of which are: (a) that an intentional felony has been committed; and (b) that the wrong done to the aggrieved party be the direct, natural and logical consequence of the felony committed by the offender.  Court found that her attempt to discredit her extrajudicial confession for the reason of her not understanding Tagalog to be flimsy, as she had lived in Manila for 14 years at this point. o Extrajudicial confessions conclusive proof, presumed voluntary until contrary is proven  On the first requisite: The Court said that this was clearly manifested “in her total indifference and seemingly unperturbed concern over the fate that had befallen the victim, being her husband (sic), especially at times when he needed her most…. The records do not show her having seen her husband even once while the latter lay seriously ill at the hospital hovering between life and death. Neither did she attend his funeral nor was she ever present during the wake…. That she was under detention does not excuse nor justify those glaring and significant omissions. For she could have asked the court's permission for any of the enumerated undertakings which we believe would not litem been denied. But she did not even attempt.”

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o Alibi not at all convincing On the second requisite: Pneumonia was merely a complication of the burns he sustained from the wife. Although pneumonia was the immediate cause of death, it could not have resulted had the victim not suffered from second degree burns. o Pneumonia not caused by alcohol, so Elias’ drinking did not bring about his death either