Case Summary (G.R. No. 170470)
Key Dates
• January 2, 2001 – Alleged commission of arson resulting in six deaths.
• January 9, 2001 – Filing of Information for arson with multiple homicide.
• October 13, 2003 – RTC Manila convicts respondent and sentences her to death.
• September 2, 2005 – Court of Appeals affirms with modification (awards damages).
• September 26, 2006 – Supreme Court decision under review.
Applicable Law
• 1987 Philippine Constitution – rights against self-incrimination and requirement of counsel during custodial interrogation (Art. III, Sec. 12).
• Presidential Decree No. 1613 (PD 1613) – defines “simple arson” and prescribes penalty of reclusion perpetua to death when death results (Sec. 5).
• Revised Penal Code, Art. 320, as amended by RA 7659 – defines “destructive arson” with mandatory death penalty if death results.
Factual Background
At around 4:45 a.m. on January 2, 2001, barangay tanods observed Edna Malngan hurriedly leaving her employer’s house at 172 Moderna Street, Tondo, Manila, boarding a pedicab. She requested stops at Nipa and Balasan Streets, appeared agitated, and paid her fare before alighting. Thirty minutes later, a fire gutted the Separa family home and six adjoining houses. The blaze killed Roberto Separa Sr., his wife Virginia, and their four children. Tanods traced the agitated woman to Balasan Street, apprehended her, and found a disposable lighter in her bag. At the barangay hall she “confessed” amid an angry crowd. She was then turned over to arson investigators.
Procedural History
An Information was filed charging respondent with arson resulting in multiple homicide. At arraignment, she pleaded not guilty. The prosecution presented eyewitness testimony, physical evidence (lighter), and extrajudicial admissions to barangay officials, a neighbor, and media outlets. Respondent filed a demurrer to evidence, deemed a waiver of her right to present evidence. The RTC denied the demurrer, found guilt beyond reasonable doubt, imposed death penalty, and awarded civil indemnity and damages. The Court of Appeals affirmed with modification—retaining the death sentence and adjusting damages. This decision was elevated for automatic Supreme Court review.
Issues
- Whether the circumstantial evidence and admissions suffice to establish guilt beyond reasonable doubt.
- Whether uncounselled extrajudicial confessions and hearsay admissions were admissible under the Constitution.
- Whether the crime should be classified as “destructive arson” under RPC Art. 320 or “simple arson” under PD 1613 and whether the death penalty remains proper.
Sufficiency of Circumstantial Evidence and Admissions
• Circumstantial evidence is sufficient if multiple proven facts combine into an unbroken chain leading to the accused’s guilt beyond reasonable doubt.
• Eyewitness Gruta identified respondent as the agitated person leaving the victim’s house shortly before the fire and uncertain of destination.
• Chairman Bernardo and other tanods corroborated her apprehension at Balasan Street and the discovery of a lighter in her possession.
• Neighbor Mendoza testified that respondent admitted setting fire with crumpled newspapers and a disposable lighter.
• Investigator Talusan overheard respondent confess on live television.
Collectively, these interlocking facts proved intentional burning of an inhabited house and linked respondent to the crime.
Admissibility of Extrajudicial Confessions
• Article III, Sec. 12(1) of the 1987 Constitution requires rights advisement and counsel presence during custodial interrogation by state agents; violations render confessions inadmissible.
• Confessions to barangay officials occurred under custodial circumstances without counsel, thus inadmissible.
• Confession to Mendoza, a private individual, and admissions broadcast on television were not obtained through state interrogation and thus fell outside the constitutional safeguard. They were properly admitted.
• Hearsay testimony of Talusan regarding televised confession was admissible under the doctrine of independently relevant statements—truth is not at issue, but the fact the statement was made.
Classification of Arson and Penalty Modification
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Case Syllabus (G.R. No. 170470)
Facts of the Case
- In the pre-dawn hours of January 2, 2001, barangay officials and residents of Balut, Tondo, Manila discovered a massive fire at No. 172 Moderna Street, owned by Roberto Separa, Sr., which quickly spread and consumed six houses.
- Victims included Roberto Separa, Sr., his wife Virginia, and their four children Michael, Daphne, Priscilla and Roberto Jr., all of whom perished from burn injuries.
- At about 4:45 a.m., pedicab driver Rolando Gruta saw Edna Malngan y Mayo (the housemaid) hastily leaving the Separa residence, looking anxious and “palipa-linga” (glancing about), then asked to be taken first to Nipa Street, and then to Balasan Street, where she alighted.
- Thirty minutes later, upon noticing the fire at the Separa house, barangay tanods—including Gruta—responded; Bernardo, the Barangay Chairman, received a report of a “confused” woman at Balasan Street, located and brought her to the barangay hall.
- Inspection of Edna’s bag revealed a disposable lighter. Under a crowd’s pressure, she confessed to barangay officials and to neighbor Mercedita Mendoza that she set the fire because she had not been paid for about a year and wanted to return to her province.
- Edna also admitted to a reporter (ABS-CBN’s Carmelita Valdez) and was overheard by SFO4 Danilo Talusan confessing on TV to crumpling newspapers, lighting them with a disposable lighter and tossing them on a table inside the house.
- An Information was filed on January 9, 2001, charging Edna with “Arson with Multiple Homicide” (Crim. Case No. 01-188424, RTC Manila, Branch 41).
Procedural History
- Arraignment: Edna pleaded “not guilty.”
- Prosecution presented five witnesses: SFO4 Danilo Talusan, Rolando Gruta, Remigio Bernardo, Mercedita Mendoza, Rodolfo Movilla, plus documentary evidence (photographs, sworn statements, arrest reports, lighter).
- Defense filed a Demurrer to Evidence without leave of court, arguing (a) no crime defined by law, (b) insufficient circumstantial evidence, and (c) hearsay testimonies.
- RTC denied the demurrer, found Edna guilty beyond reasonable doubt of Arson with