Case Digest (G.R. No. L-35574)
Facts:
People of the Philippines charged Valentina Mananquil y Laredo with parricide for pouring gasoline on and setting aflame her husband, Elias Day y Pablo, at the NAWASA building in Pasay on March 6, 1965; the victim died on March 10, 1965, and the trial court convicted appellant and sentenced her to reclusion perpetua with indemnity and costs. Appellant gave a written extrajudicial statement shortly after the incident admitting the act, later recanted at trial, and appealed the conviction to the Court of Appeals which referred the case to the Supreme Court.Issues:
- Was appellant's written extrajudicial confession voluntarily given and admissible?
- Did the burns inflicted by appellant contribute to the victim's death by pneumonia so as to sustain criminal liability?
Ruling:
The Court affirmed the conviction and sentence of reclusion perpetua, finding the extrajudicial conf Case Digest (G.R. No. L-35574)
Facts:
- Nature and procedural history
- People of the Philippines filed an amended Information charging Valentina Mananquil y Laredo with parricide allegedly committed on March 6, 1965.
- The original Information filed March 8, 1965 charged frustrated parricide; the amended Information charged parricide.
- Upon arraignment, the accused pleaded "NOT GUILTY."
- The trial court convicted the accused and sentenced her to reclusion perpetua; ordered indemnity to the heirs in the amount of P12,000.00; and imposed costs.
- The accused appealed to the Court of Appeals; the appeal was referred to the Supreme Court because the penalty imposed was reclusion perpetua.
- Prosecution's factual narrative
- On March 6, 1965 at about 11:00 p.m., appellant went to the NAWASA building in Pasay City where her husband, Elias Day y Pablo, worked as a security guard.
- Appellant had purchased ten centavos worth of gasoline from an Esso station, placed it in a coffee bottle, and brought it with her.
- Appellant was allegedly angry because her husband burned her clothing, maintained a mistress, and took food from their house.
- Upon the victim opening the door and shouting insults, appellant poured gasoline on his person and ignited his polo shirt, causing burns.
- Appellant was investigated by Pasay City police and gave a written statement (Exhs. "A" and "A-1") admitting the burning.
- The victim was taken to the Philippine General Hospital then to Trinity General Hospital and died on March 10, 1965; necropsy report listed "Pneumonia, lobar bilateral. Burns 2 secondary."
- Appellant's defense narrative
- Appellant claimed she returned from Olongapo before 10:00 p.m., fed her grandson, and bought gasoline to clean her shoes and to supply her husband's lighter.
- She stated she went to NAWASA to deliver gasoline; the husband, allegedly drunk, cursed her; she became dizzy and did not know she was sprinkling gasoline on him.
- She alleged police later accused her of burning her husband, took her to headquarters, and induced her to sign Exhibits "A" and "A-1" by promising she would be released if she signed, despite her not knowing the contents.
- Evidence relating to the extrajudicial confession and investigation
- Sgt. Leopoldo Garcia of the Pasay City Police took appellant's statement in Tagalog in question-and-answer form, reduced to writing (Exhs. "A" and "A-1").
- Appellant was brought before Fiscal Paredes, who questioned her and before whom she subscribed and swore to the statement.
- The written statement contains detailed admissions that appellant bought gasoline, poured it on her husband, and set his shirt aflame.
- On cross-examination, appellant admitted she could understand and read Tagalog and had lived in Manila s...(Subscriber-Only)
Issues:
- Voluntariness and evidentiary weight of the extrajudicial confession
- Whether appellant's extrajudicial confession (Exhs. "A" and "A-1") was voluntarily given and whether it could serve as a basis for conviction.
- Causation of death and criminal liability
- Whether the burns inflicted by appellant contributed to the pneumonia that caused the victim's death.
- Whether any intervening cause, such as alcohol consumption or medical complications, negated appellant's criminal liability for the death.
- Sufficiency of evidence and reas...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)