1
L-35574
People v. Mananquil1
Criminal Liability / How Incurred / Wrongful Act Done Different from What was Intended2
Date: September 28, 19843
Ponente: Cuevas, J.
SUMMARY:
The appellant, Valentina Mananquil, was convicted by
the CFI Rizal of parricide and sentenced to reclusion
perpetua. She went on her husband’s workplace and
poured gasoline over the latter which she ignited. Her
husband, Elias Day, suffered 2nd Degree burns to about
62% of his body which eventually lead to pneumonia
and death.
During the trial, the CFI primarily based its decision on
the appellant’s extrajudicial confession. Said
confession’s admissibility was questioned by the
appellant on her appeal. However, the Court held the
admissibility of the confession and affirmed the CFI’s
decision.
ISSUES:
1. WoN the appellant’s extrajudicial confession
was voluntary given
2. WoN the burns sustained by the victim
contributed to cause pneumonia which was the
cause of death of the victim
FACTS:
1. On the evening of 06 March 1965, appellant
bought 10 centavos worth of gasoline from Esso
Gasoline Station at Taft Ave.; and went to the
NAWASA Building in Pasay City, where her
husband worked as a security guard.
2. Upon seeing the appellant, her husband shouted
at her and castigated her.
3. Tired of hearing her husband, she poured the
gasoline over and ignited it.
4. The appellant’s husband was brought to the
Philippine General Hospital and later transferred
to the Trinity General Hospital where he
eventually died.
5. The Pasay City police investigated the appellant
wherein she gave a written statement admitting
what she has done to her husband.
6. The appellant never visited her husband during
the latter’s hospital confinement, wake, and
funeral.
HOLDING:
1. Yes. There were no records to prove otherwise.4
a. The appellant recounted the contents of her
sworn statement during the trials.
b. Contrary to the appellant’s claim that she
cannot understand Tagalog, she has lived in
Manila since 1951.
c. The appellant’s action disclaiming any
responsibility for the burning of her
husband, which is contrary to her initial
statements, only came 4 years after the
incident.
2. Yes. The pneumonia which caused the appellant’s
husband’s death was a mere complication of the
burns he suffered at the hand of the appellant.
a. The appellant is criminally responsible for
the natural consequences of her criminal
act (i.e. burning her husband) under Article
4, Paragraph 1 of the Revised Penal Code5.
RULING:
The judgment appealed from is hereby AFFIRMED.6
(The appellant was convicted of parricide and sentenced to
reclusion perpetua and to indemnify the heirs of the deceased
in the amount of PhP 30,000.00.
However, since the appellant was already 71 years of age, the
Court recommended her for executive clemency by the
President.)
2
Article 4, Paragraph 1, Revised Penal
Code
3
In Effect: Revised Penal Code
4
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. The burden of
proof is upon the person who gave the
confession.
5
Article 4, Revised Penal Code:
“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.
(2) By any person performing an act
which would be an offense against
persons or property, were it not for
this inherent impossibility of its
accomplishment or on account of the
employment of inadequate or
ineffectual means.”
6
Case was decided by the Second Division,
without dissent.