People v Mananquil digest

People v. Mananquil GR No L-35574, Sep 28, 1994, Cuevas, J. Dean Lozarie

Law 109 – Crim 1

Group B5

FACTS 

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Prosecution’s version o 1965 Mar 6: At about 11pm, Valentina Manananquil went to the NAWASA Building at Pasay City, where her husband was working as a security guard o She had just purchased 10 centavos worth of gasoline from the Esso Gasoline Station at Taft Avenue. She placed the gasoline in a coffee bottle o She was angry at her husband, Elias Day, because the latter had burned her clothing, was maintaining a mistress, and had been taking all the food from their house o Upon reaching the NAWASA Building, she knocked at the door o Immediately after the door was opened, Elias Day shouted at his wife and castigated her, saying ―PUTA BUGUIAN LAKAW GALIGAON‖ o The appellant, tired of hearing the victim, then got the bottle of gasoline and poured the contents thereof on the face of the victim o Then, she got a matchbox and set the polo shirt of the victim aflame Defense’s version o Taking with her an empty bottle of Hemo, she left for a nearby gasoline station and bought ten centavos’ worth of gasoline, intending to use the same to clean her shoes, which she needed for church the next day o Then she remembered that her husband needed gasoline for his lighter so she dropped by his place of work o She saw her husband inside a building of the NAWASA standing by the window o She entered and knocked at the wooden door. Elias opened the door, but when he saw his wife he shouted at her. o She told him that she had brought him fluid for his lighter, but Elias, who was drunk, cursed her ―PUTA BUGUIAN LAKAW GALIGAON.‖ This shouting continued despite her telling him that she had come just to bring the gasoline that he wanted o She trembled and became dizzy. She was beside herself and did not know that she was sprinkling the gasoline on her husband’s face. o She was tired and dizzy and had to sit down for a while. Then she remembered her grandson who was alone in the house so she went home, leaving her husband who was walking to and fro and not paying attention to her o She went to bed but could not sleep. She returned to NAWASA to apologize to her husband, but, upon arriving, saw that police officers were present o An officer pulled her aside, asked her if she was Elias’s wife o When she said yes, officer accused her of setting her husband on fire—an accusation she denied

o The police took her to the headquarters, prepared a written statement which she was made to sign upon a promise that she would be released if she signed it

ISSUES/HELD WON appellant’s extrajudicial confession was voluntarily given – YES WON burns sustained by victim contributed to cause pneumonia which was the cause of the victim’s death – YES

RATIONALE      

Court found ―appellant’s aforesaid assertions a mere pretense to flimsy to be accepted as true,‖ ―no error in the trial court’s pronouncement that the appellant’s sworn statement was voluntarily given by her‖ Contrary to her claim, she knew and understood Tagalog even though she was not a ―Tagala‖ as she had stayed in Manila continuously for 14 years her total indifference and seemingly unperturbed concern over the fate that had befallen the victim supports the theory that she ―has murder in her heart and meant to do harm‖ to her husband Mananquil claimed that victim’s pneumonia, from which he died, was caused by the alcohol which he was drunk on that night. But as testified by a doctor, taking alcohol cannot cause pneumonia Pneumonia was complication of the burns sustained While accepting pneumonia as the immediate cause of death, the court held on to state that this could not have resulted had not the victim suffered from second-degree burns