People v Mananquil

G.R. No. L-35574, September 28, 1984G.R.

Topic: Criminal liability| How incurred | Wrongful act done be different from what was intended
Plaintiff-appellee: People of the Philippines
Defendant-appellant: Valentina Mananquil
Action and ponente: Cuevas,

Facts
Convicted of parricide for killing husband - pled not guilty, convicted to reclusion perpetua, 12k indemnity
- CA referred appeal to SC contending that the trial court erred: 1) in convicting her solely on the basis of the alleged
extrajudicial confession;
2) in finding that Pneumonia was a complication of the burns sustained by the victim;
3) in not finding her not to have caused the death of the deceased; and
4) in not acquitting her at least on ground of reasonable doubt.

Prosecution version: 11pm she went to the Nawasa after purchasing 10 centavos worth of gasoline from the Esso Gasoline
station at taft avenue, which she placed in a coffee bottle. She was angry at her husband, Elias Day y Pablo, because the
latter had burned her clothing, was maintaining a mistress and had been taking all the food from their house. After knocking
on the door, it was immediately opened and husband shouted at her "PUTA BUGUIAN LAKAW GALIGAON". She poured the
contents on him and got a matchbox and set the polo shirt on fire.
Defense version: Before 10pm she returned from Olongapo, fed and put her grandson to bed. After filling the tank with
water, she remembered that the next day was a Sunday and she had to go to church. Her shoes were dirty but there was no
gasoline with which to clean them. She took an empty bottle of Hemo and bought 10 cents worth of gasoline, then
remembered that her husband needed gasoline or his lighter so she dropped by. Appellant saw her husband inside a building
of the NAWASA standing by the window. As the iron grille was open, she entered and knocked at the wooden door. Appellant
said that she had brought the gasoline which he needed for his lighter, but Elias, who was under the influence of liquor,
cursed her thus: 'PUTA BUGUIAN LAKAW GALIGAON'. She trembled and became dizzy, and was beside herself. She did not
know that she was sprinkling gasoline on his face she was dizzy and had to sit down for a while, and remembered that her
grandson was alone in the house so she left, leaving her husband walking to and fro and ignoring her. She went to bed but
could not sleep. She went back to the NAWASA compound to apologize but saw police officers present. Her husband was
walking all around still fuming mad, and when he saw her he chased her. A policeman pulled appellant aside and asked if she
was the wife of Elias. When she replied in the affirmative, the police officer accused her of burning her husband. She denied
the accusation. But the police took her to the headquarters, and prepared a written statement, and was made to sign the
statement upon promise of her release. She signed it even without knowing what was in the statement.

Sgt Leopoldo Garcia tool her statement in tagalog in q&a form. then she was brought to fiscal paredes who asked her some
questions then made her subscribe and swear to the statement. Mananquil wants to discredit her extrajudicial confession
because she did not understand the contents as she is not a tagala, and reached on primary school and she only signed it
upon promise of her release.
Issue
(1) whether or not appellant's extrajudicial confession was voluntarily given; and
(2) whether or not the burns sustained by the victim contributed to cause pneumonia which was the cause of the victim's
death.
HELD: yes to both. judgment affirmed, indemnity increased to 30k.

WHEREFORE, except as thus modified, the judgment appealed from is hereby AFFIRMED with costs against appellant.

It appearing however that appellant Valentina Mananquil is now 71 years of age, this Court recommends her for executive
clemency. For the purpose, let His Excellency, President Ferdinand E. Marcos, be furnished with a copy of this decision thru
the Hon. Minister of Justice.

RULE: Art. 4. Criminal Liability. - 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."

Ratio: Mananquils assertions too flimsy. She actually knew Tagalog, having stayed in Manila since 1951 and was in daily
association with Tagalogs and she admitted during cross-examination that she was well understood by tagalogs. She also did
not complain against the police officers for making her sign. For why will the police still resort to such trickery when the very
sworn statement given by her proved by its contents that appellant was indeed very cooperative. Her testimony repeated
what was in the statement. The said statement replete with details which could not have been possibly supplied by the
police investigators who have no previous knowledge of, nor acquaintance with her and the victim, especially with respect to
the circumstances and incidents which preceded the fatal incident that brought about the death of the latter.
Well settled is the rule that extrajudicial confession may be regarded as conclusive proof of guilt when taken without
maltreatment or intimidation and may serve as a basis of the declarant's conviction. It is presumed to be voluntary until the
contrary is proven. It was taken right after the indient and no time to fabricate any detail favorable to her, and shock made
her admit the undeniable. The burden of proof is upon the person who gave the confession. She only testified more than 5
years after the incident in 1969 after having the benefit of too many consultations.
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. She could have asked
the court to let her attend the wake or funeral or hospital.
Purpose of buying gasoline so late at night was absurd. Also, mananquil wants the court to believe that her husband died of
pneumonia due to liquor drinking in the hospital and not due to burning. A doctor testified that pneumonia could not have
been caused by alcohol -- In fact, alcohol, according to him, unless taken in excessive dosage so as to produce an almost
comatose condition would not cause suffocation nor effect a diminution of the oxygen content of the body. OSG: liquor was
not an efficient supervening cause of his death which took place on March 10, 1965, just four days after the burning.
Pneumonia caused by 2nd degree burns covering 62 percent of the body complication of the burns.

Rule 4 art 1: 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
One who inflicts injury on another is deemed guilty of homicide if the injury contributes immediately or immediately to the
death of such other. The fact that other causes contribute to the death does not relieve the actor of responsibility. He would
still be liable "even if the deceased might have recovered. every person is held to contemplate and be responsible for the
natural consequences of his own acts. Amidst the conflicting theories of medical men and the uncertainties attendant upon
the treatment of bodily ailments and injuries it would be easy in many cases of homicide to raise a doubt as to the
immediate cause of death, and thereby open a wide door by which persons guilty of the highest crime might escape
conviction and punishment."