People V Malngan

Facts: Barangay Officials discovered that a fire gutted the house of Edna Malngan’s employer. Chairman
received a report from pedicab driver, that shortly before the fire, he saw Edna leaving the house. They
found Edna and confessed that she set the house on fire because she had not been paid her salary for a
year and she was not permitted to go home to her province. Edna was turned over to arson
investigators. When Mercedita Mendoza went to the Fire Station to give her sworn statement, she
asked Edna why and how she did it, Edna replied because when she was denied to go home, and that
she crumpled newspapers, lighted them with a disposable lighter and threw them on the table.

Issue: WON the all confession without the assistance of competent and independent counsel of the
appellant-accused is inadmissible as evidence.

Held: No. Accused-appellants confession to Barangay Chairman Remigio Bernardo was made in
response to the interrogation without first informing Edna of her rights under the Constitution or done
in the presence of counsel. The confession, as well as the lighter found in her bag are inadmissible.

The testimony of Mercedita recounting said admission is admissible in evidence against her and is not
covered by the constitutional guarantee.