Primary Holding
An extrajudicial confession is presumed voluntary until the contrary is proven, and the burden of proof rests on the person who gave it; it may be conclusive proof of guilt when taken without maltreatment or intimidation. Under Article 4(1) of the Revised Penal Code, one who commits a felony is criminally liable for the natural and logical consequences of the wrongful act even if another cause contributes to the death.
Background
Valentina Mananquil y Laredo and Elias Day y Pablo were spouses. Elias worked as a security guard at the NAWASA building in Pasay City. The legal backdrop includes Article 4(1) of the Revised Penal Code, which imposes criminal liability for a felony although the wrongful act done be different from that intended, and the rule that an extrajudicial confession is presumed voluntary until the contrary is proven.
History
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Original Information for frustrated parricide filed on March 8, 1965 before the then Court of First Instance of Rizal.
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Amended Information for parricide filed before the then Court of First Instance of Rizal.
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Accused arraigned and pleaded not guilty.
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Trial court convicted accused, sentenced her to reclusion perpetua, ordered indemnity of P12,000 to the heirs, and imposed costs.
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Accused appealed to the then Court of Appeals, which referred the appeal to the Supreme Court because the penalty imposed was reclusion perpetua.
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Supreme Court affirmed the judgment with modification, increasing the indemnity to P30,000, and recommended appellant for executive clemency.
Facts
Valentina Mananquil y Laredo and Elias Day y Pablo were lawfully married. Elias worked as a security guard at the NAWASA building in Pasay City. On March 6, 1965, at about 11:00 p.m., Valentina went to the NAWASA building. According to the prosecution, she had just purchased ten centavos worth of gasoline from the Esso Gasoline Station at Taft Avenue and placed it in a coffee bottle. She was angry with Elias because he had burned her clothing, was maintaining a mistress, and had been taking all the food from their house. Upon reaching the NAWASA building, she knocked at the door. When Elias opened it, he shouted at and castigated her, saying “PUTA BUGUIAN LAKAW GALIGAON.” Tired of hearing him, she poured the gasoline on his face, got a matchbox, and set his polo shirt aflame. She was investigated by Pasay City police and gave a written statement admitting that she had burned the victim.
The victim was taken first to the Philippine General Hospital and then to Trinity General Hospital at Sta. Ana, Manila, where he died on March 10, 1965. The cause of death shown by the necropsy report was pneumonia, lobar bilateral, Burns 2' secondary. The post-mortem findings referred to burns covering about 62% of the victim’s entire body. Dr. Reyes testified that pneumonia could not be caused by taking alcohol; alcohol, unless taken in excessive dosage so as to produce an almost comatose condition, would not cause suffocation or diminish the oxygen content of the body. The trial court found that pneumonia was a mere complication of the burns and that, although pneumonia was the immediate cause of death, it could not have resulted had the victim not suffered second degree burns; with pneumonia having developed, the burns became contributory to the cause of death.
Valentina gave a different account. She testified that before 10:00 p.m. she returned from Olongapo City, fed her grandson, and put him to bed. After filling the tank with water, she remembered that the next day was Sunday and she had to go to church; her shoes were dirty but there was no gasoline with which to clean them. Taking an empty bottle of Hemo, she left for a nearby gasoline station and bought ten centavos worth of gasoline. She then remembered that her husband needed gasoline for his lighter, so she dropped by his place of work. She saw Elias inside the NAWASA building standing by the window. As the iron grille was open, she entered and knocked at the wooden door. Elias opened the door, but when he saw her he shouted at her. She said she had brought the gasoline he needed for his lighter, but Elias, who was under the influence of liquor, cursed her. He continued shouting and cursing even as she told him she had come only to bring the gasoline. She trembled and became dizzy; she was beside herself and did not know that she was sprinkling the gasoline on her husband’s face. She sat down for a while, then remembered her grandson alone in the house and went home, leaving her husband walking to and fro. She went to bed but could not sleep, and returned to the NAWASA compound to apologize. Upon reaching it, however, she found police officers present; her husband was still fuming mad and chased her when he saw her. A policeman pulled her aside and asked if she was Elias’s wife; when she replied in the affirmative, the officer accused her of burning her husband. She denied the accusation, but the police took her to headquarters and prepared a written statement, Exhibits A and A-1. She signed it upon a promise that she would be released if she signed; although she did not know its contents, she signed because of the promise.
After the burning incident, Valentina was picked up by Pasay City police operatives. She was investigated by Sgt. Leopoldo Garcia, who took her statement in Tagalog in question-and-answer form and reduced it to writing. After Sgt. Garcia finished, she was brought to Fiscal Paredes, who asked her questions regarding the statement and its execution, and before whom she subscribed and swore to the statement. In that statement she categorically admitted having thrown gasoline at her husband and thereafter setting him aflame. She stated that because her husband had burned her clothes, had a woman, and had been hauling away their food, her mind darkened and she thought of pouring gasoline on him; she bought ten centavos worth at the Esso Gasoline Station at Taft Avenue, placed it in a bottle, went to the NAWASA building, knocked, and after her husband opened the door and cursed her, she took the bottle of gasoline, poured it on his body, got a match, and lit his polo shirt, which flamed. She admitted, “aking sinunog ang aking asawa.” She later claimed that she did not understand the contents of the statement because she was not a Tagala and had reached only the primary grades, and that she signed it only upon the policemen’s promise that she would later be released.
The trial court rejected those claims. It found that Valentina knew and understood Tagalog despite not being a Tagala, having stayed in Manila since 1951 continuously up to the time of the incident, almost fourteen years, during which she was in daily association with Tagalogs and communicated with them in Pilipino. On cross-examination she admitted that she could understand, speak, and read Tagalog. During the entire investigation, and even before Fiscal Paredes, she made no denunciation against the police investigators and aired no complaint that she had signed merely because of a promise of release. The trial court found her claim highly incredible and a mere concoction, and found the sworn statement replete with details that the police investigators could not have supplied. It also noted that when she took the witness stand disclaiming responsibility, it was already January 13, 1969, more than five years after the incident. The trial court further found her indifferent to the victim’s fate: she did not see her husband even once while he lay seriously ill in the hospital, did not attend his funeral, and was not present during the wake; her detention did not excuse those omissions because she could have asked the court’s permission. It likewise found her explanation—that she bought gasoline past ten o’clock in the evening solely to clean her shoes for church the following Sunday and dropped by her husband’s workplace in the middle of the night only to deliver gasoline for his cigarette lighter—hard to accept, especially considering the previous spat she had with the deceased on the morning of that fatal day.
The amended Information charged Valentina with parricide, alleging that on or about March 6, 1965, in Pasay City, with evident premeditation, she entered the NAWASA building where Elias worked as a security guard, poured gasoline on him, and ignited it, causing burns and injuries that subsequently caused his death. The original Information filed on March 8, 1965 had charged only frustrated parricide. She pleaded not guilty. The trial court found the extrajudicial confession voluntarily given and the burns contributory to the death.
Arguments of the Petitioners
- Extrajudicial Confession: Appellant argued that the trial court erred in convicting her solely on the basis of the alleged extrajudicial confession; she maintained that the confession was not voluntarily given because she did not understand its contents, not being a Tagala and having reached only the primary grades, and because she signed it only upon the police’s promise that she would be released.
- Causation of Death: Appellant argued that the trial court erred in finding that pneumonia was a complication of the burns; she claimed her husband died of pneumonia because he drank liquor, as shown by the toxicology report indicating alcohol in his body, and that assuming she set him on fire, she was not criminally liable for his death.
- Reasonable Doubt: Appellant contended that she should be acquitted at least on the ground of reasonable doubt.
Arguments of the Respondents
- Causation: The People, through the Solicitor General, maintained that the victim’s taking of liquor was not an efficient supervening cause of his death; pneumonia could not be caused by alcohol, and the burns sustained by the victim contributed to his death.
Issues
- Voluntariness of Extrajudicial Confession: Whether the extrajudicial confession was voluntarily given and could be made the basis of conviction.
- Causation of Death: Whether the burns sustained by the victim contributed to cause pneumonia, the immediate cause of his death, such that appellant is criminally liable for parricide.
Ruling
- Voluntariness of Extrajudicial Confession: Yes. The extrajudicial confession was presumed voluntary until the contrary was proven, and appellant failed to overcome that presumption; it could serve as conclusive proof of guilt.
- Causation of Death: Yes. The burns contributed to the victim’s death; pneumonia was a complication of the burns, and under Article 4(1) of the Revised Penal Code the appellant is liable although the wrongful act done was different from that intended.
Ruling Rationale
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Voluntariness of Extrajudicial Confession: The Court found appellant’s assertions flimsy. She knew and understood Tagalog despite not being a Tagala, having stayed in Manila since 1951 continuously up to the incident, almost fourteen years, during which she was in daily association with Tagalogs and communicated with them in Pilipino. On cross-examination she admitted that she could understand, speak, and read Tagalog. During the entire investigation and even before Fiscal Paredes, she made no denunciation against the police investigators and aired no complaint that she had signed merely because of a promise of release. Her claim was incredible; the police would not resort to such trickery when the sworn statement itself showed her cooperation. Almost all recitals in the statement were repeated by her on the witness stand, and the statement was replete with details that the police investigators could not have supplied. The trial court correctly found the statement voluntarily given, fully understood, and willingly signed. The rule is that an extrajudicial confession may be regarded as conclusive proof of guilt when taken without maltreatment or intimidation and may serve as a basis of conviction; it is presumed voluntary until the contrary is proven, with the burden of proof on the person who gave it. That presumption was not overcome. The trial court could rely heavily on the sworn statement because it was given shortly after the incident, before appellant had time to concoct a fabrication; when she testified disclaiming responsibility, it was already January 13, 1969, more than five years after the incident. Her indifference also supported the finding: she did not see her husband while he was seriously ill, did not attend his funeral, and was not present during the wake; detention did not excuse those omissions because she could have asked the court’s permission. Her explanation about buying gasoline past ten o’clock in the evening to clean her shoes for church and dropping by her husband’s workplace in the middle of the night to deliver gasoline for his lighter was likewise too taxing upon credulity, especially considering the previous spat that morning.
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Causation of Death: Appellant claimed the victim died of pneumonia because he drank liquor, as shown by the toxicology report indicating alcohol in his body. The Court was not persuaded. Dr. Reyes testified that pneumonia could not be caused by taking alcohol; alcohol, unless taken in excessive dosage so as to produce an almost comatose condition, would not cause suffocation or diminish the oxygen content of the body. The Solicitor General correctly pointed out that the victim’s taking of liquor was not an efficient supervening cause of his death, which took place on March 10, 1965, just four days after the burning. The cause of death shown by the necropsy report was pneumonia, lobar bilateral, Burns 2' secondary. The burns sustained by the victim covered about 62% of his entire body, and pneumonia was a mere complication of the burns. While pneumonia was accepted as the immediate cause of death, it could not have resulted had the victim not suffered second degree burns; with pneumonia having developed, the burns became contributory to the cause of death. Appellant’s case falls squarely under Article 4, paragraph 1, of the Revised Penal Code, which provides that criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which he intended. The essential requisites are: (a) an intentional felony has been committed; and (b) the wrong done to the aggrieved party is the direct, natural, and logical consequence of the felony committed by the offender. Citing PP vs. Moldes and PP vs. Quianzon, the Court reiterated that one who inflicts injury on another is guilty of homicide if the injury contributes immediately or immediately to the death; the fact that other causes contribute to the death does not relieve the actor of responsibility. Every person is held to contemplate and be responsible for the natural consequences of his own acts. Thus, the burns inflicted by appellant were the intentional felony, and the pneumonia and death were the direct, natural, and logical consequences of that felony.
Doctrines
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Presumption of Voluntariness of Extrajudicial Confession — An extrajudicial confession is presumed voluntary until the contrary is proven; the burden of proof is on the person who gave the confession. It may be regarded as conclusive proof of guilt when taken without maltreatment or intimidation and may serve as a basis of conviction. The Court applied this doctrine by finding that appellant failed to overcome the presumption: she understood Tagalog, made no denunciation or complaint during investigation or before the fiscal, subscribed and swore to the statement, and included details only she could have supplied.
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Criminal Liability for Natural and Logical Consequences of a Felony under Article 4(1), Revised Penal Code — Under Article 4(1), criminal liability is incurred by any person committing a felony although the wrongful act done be different from that which he intended. The essential requisites are: (a) an intentional felony has been committed; and (b) the wrong done to the aggrieved party is the direct, natural, and logical consequence of the felony committed by the offender. The Court applied this doctrine because appellant intentionally poured gasoline on her husband and ignited him; the pneumonia and death were direct, natural, and logical consequences of the burns, and the victim’s taking of liquor was not an efficient supervening cause.
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Efficient Supervening Cause — A cause that intervenes to break the causal chain between the felony and the resulting harm. The Court held that the victim’s taking of liquor was not an efficient supervening cause of death because pneumonia could not be caused by alcohol, and the burns remained a contributory cause of the pneumonia and death.
Key Excerpts
- “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. The burden of proof is upon the person who gave the confession.” — This passage states the controlling rule on extrajudicial confessions and explains why the conviction could rest on appellant’s sworn statement.
- “Appellant's case falls squarely under Art, 4, Par. 1 of the Revised Penal Code which provides: 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.” — This excerpt identifies the statutory basis for liability notwithstanding the different wrongful act that resulted in death.
- “The fact that other causes contribute to the death does not relieve the actor of responsibility.” — This passage, quoted from the cited precedents, is the core causation principle applied to reject appellant’s argument that pneumonia from liquor absolved her.
- “In fine, as correctly pointed out by the Hon. Solicitor General, the victim's taking of liquor was not an efficient supervening cause of his death which took place on March 10, 1965, just four days after the burning.” — This excerpt directly disposes of appellant’s supervening-cause defense and ties the death to the burns.
Precedents Cited
- PP vs. Moldes, 61 Phil. 1, 3 & 4 — Cited for the rule that one who inflicts injury on another is guilty of homicide if the injury contributes to death, and that other causes contributing to the death do not relieve the actor of responsibility.
- PP vs. Quianzon, 62 Phil. 162 — Cited with Moldes for the same causation principle, quoting 13 RCL 748, 751.
- PP vs. Pincalin, 102 SCRA 137 — Cited for the rule that an extrajudicial confession may be regarded as conclusive proof of guilt when taken without maltreatment or intimidation.
- PP vs. Carias, 122 SCRA 783 — Cited for the same rule on extrajudicial confessions.
- PP vs. Perez, 102 SCRA 313 — Cited for the rule that an extrajudicial confession may serve as a basis of the declarant’s conviction.
- PP vs. dela Cruz, 115 SCRA 154 — Cited for the presumption that an extrajudicial confession is voluntary until the contrary is proven, with the burden of proof on the person who gave it.
- US vs. Brobst, 14 Phil. 310 — Cited for the essential requisites of Article 4, paragraph 1, of the Revised Penal Code.
- US vs. Mallare, 29 Phil. 14 — Cited with Brobst for the essential requisites of Article 4, paragraph 1.
Provisions
- Article 4, paragraph 1, Revised Penal Code — Criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which he intended. The Court applied this provision because appellant committed the intentional felony of pouring gasoline on her husband and igniting him; the resulting pneumonia and death were the direct, natural, and logical consequences of that felony, and other contributing causes did not relieve her of liability.
Notable Concurring Opinions
Makasiar (Chairman), Aquino, Abad Santos, and Escolin, JJ., concurred. Concepcion, Jr. and Guerrero, JJ., were on leave.