People v.

Mananquil
GR No L-35574, Sep 28, 1994, Cuevas, J.

Dean Lozarie Law 109 Crim 1 Group B5

FACTS

Prosecutions 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
Defenses 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 husbands 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 Eliass wife
o When she said yes, officer accused her of setting her husband on firean
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 appellants extrajudicial confession was voluntarily given YES
WON burns sustained by victim contributed to cause pneumonia which was the cause of the
victims death YES

RATIONALE

Court found appellants aforesaid assertions a mere pretense to flimsy to be accepted as
true, no error in the trial courts pronouncement that the appellants 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 victims 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