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

Dean Lozarie Law 109  – Crim 1 Group B5

FACTS

  Prosecution’s 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
o
reachingafter
Immediately the NAWASA Building,
the door was she Elias
opened, knocked at the
Day door at his wife and
shouted
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

  Defense’s 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

o  dropped
She saw by
herhis place of
husband worka building of the NAWASA standing by the window
inside
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 husband’s face. 

o  She was tired and dizzy and had to sit down for a while. Then she remembered

her
whograndson whoto
was walking was
andalone in the
fro and nothouse
payingsoattention
she wenttohome,
her leaving her husband
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 Elias’s wife 

o  When she said yes, officer accused her of setting her husband on fire —  an
accusation she denied

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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 appellant’s extrajudicial confession was voluntarily given –  YES

WON burns sustained by victim contributed to cause pneumonia which was the cause of the
victim’s death –  YES

RATIONALE

  Court found ―appellant’s aforesaid assertions a mere pretense to flimsy to be accepted as

true,‖ ―no error in the trial court’s pronouncement that the appellant’s 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 victim’s 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

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