Case Digest (G.R. No. 170470)
Facts:
People of the Philippines v. Edna Malngan y Mayo, G.R. No. 170470, September 26, 2006, Supreme Court En Banc, Chico‑Nazario, J., writing for the Court.Appellant Edna Malngan y Mayo was charged by Information filed on January 9, 2001 before the Regional Trial Court (RTC) of Manila, Branch 41 (Criminal Case No. 01‑188424), with “Arson with Multiple Homicide” for allegedly setting fire to her employer’s two‑storey house at No. 172 Moderna St., Balut, Tondo, Manila on January 2, 2001, by lighting crumpled newspapers with a disposable lighter; the blaze destroyed several houses and resulted in the deaths of six members of the Separa family. She pleaded not guilty and trial ensued.
Eyewitness testimony at trial placed Edna hurrying out of the Separa house at about 4:45 a.m., boarding a pedicab and alighting a short time later at Balasan Street; a pedicab driver and the barangay chairman identified her. The barangay chairman and tanods apprehended her, opened her bag and found a disposable lighter. Several witnesses recounted that Edna admitted to setting the fire: she allegedly confessed to a neighbor, Mercedita Mendoza, and her statements were also reported to have been made before media (ABS‑CBN reporter Carmelita Valdez and on the TV program “True Crime” hosted by Gus Abelgas). Arson investigator SPO4 Danilo Talusan heard the media reports and testified as to the confessions he heard via broadcast.
During trial Edna filed a Demurrer to Evidence (without express leave of court). On October 13, 2003 the RTC denied the demurrer, found appellant guilty beyond reasonable doubt of arson resulting in multiple deaths, and sentenced her to death; it ordered civil indemnities and damages. Because of the death penalty, the record was referred to the Supreme Court for automatic review but, under People v. Mateo, it was first transmitted to the Court of Appeals (CA) for appropriate action.
On September 2, 2005 the Court of Appeals affirmed with modification: it confirmed conviction but modified the damages awards (ordering additional moral and exemplary damages for the victims and reducin...(Subscriber-Only)
Issues:
- Was the evidence presented by the prosecution sufficient to convict appellant beyond reasonable doubt?
- Were the extrajudicial admissions/confessions and related testimony (the barangay confession, the lighter found in appellant’s bag, and statements reported to the media) admissible in evidence?
- Was appellant properly charged with a complex crime of “Arson with Multiple Homicide,” and what is the corre...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)