Facts:
The Incident and Arrest
Around 4:45 a.m. on January 2, 2001, Barangay Chairman Remigio Bernardo and his tanods
observed a woman, later identified as Edna Malngan y Mayo, leaving the house of her employer,
Roberto Separa, Sr. at No. 172 Moderna Street, Balut, Tondo, Manila.
The accused, employed as a housemaid, displayed unusual behavior—turning her head in
different directions and appearing agitated—as she hurriedly departed in a pedicab driven by
Rolando Gruta.
Initially, she requested to be taken to Nipa Street but then changed her destination to Balasan
Street.
Approximately thirty minutes later, the fire engulfed the house of the Separa family, which also
spread to adjoining houses.
Evidence at the Scene and Immediate Investigation
Upon arrival at the barangay hall, the tanods and Barangay Chairman Bernardo, assisted by
Rolando Gruta, apprehended the accused based on her conspicuous behavior and identification
by neighbors.
A disposable lighter was found in her bag during the subsequent investigation.
The accused verbally confessed to setting the fire, stating that she did so because she had not
been paid her salary for almost a year and, when she asked for permission to go home, she was
ridiculed by her employer’s wife.
Testimonies and Documentary Evidence
Several witnesses testified:
SPO4 Danilo Talusan, an arson investigator, testified that he heard confessions by the accused
during media interviews on Channel 2 (ABS-CBN) and during a later telecast ("True Crime"
hosted by Gus Abelgas).
Rolando Gruta, the pedicab driver, testified about observing her hurried departure and
subsequent nervous behavior.
Barangay Chairman Remigio Bernardo testified regarding the investigation at the barangay hall,
including the discovery of her bag containing a lighter and the accused’s admission under
pressure.
Mercedita Mendoza, a nearby resident whose house was also burned, identified the accused and
recounted an additional statement linking the accused’s actions to a provocative comment by
her employer.
The prosecution also introduced documentary evidence such as photographs of the victims, the
burned houses, crime reports, booking and arrest records, and other exhibits.
Procedural Developments
On January 9, 2001, an Information was filed before the RTC of Manila charging Edna Malngan
y Mayo with Arson with Multiple Homicide (the death of six individuals, including Roberto
Separa, Sr., his wife Virginia, and their four children).
During trial proceedings, the prosecution presented multiple witnesses to establish the
circumstantial evidence and the accused’s confessions.
The defense, through a Motion to Admit Demurrer to Evidence and a corresponding Demurrer,
argued the insufficiency of evidence, the hearsay nature of certain testimonies, and the violation
of constitutional rights regarding uncounselled confessions.
The RTC proceeded with the trial despite the defense’s motion, considering it a waiver of the
right to present additional exculpatory evidence.
Decisions of Lower Courts
The RTC found Edna Malngan y Mayo guilty beyond reasonable doubt of Arson with Multiple
Homicide, imposing the death penalty along with civil indemnities and damages for the victims'
heirs.
On September 2, 2005, the Court of Appeals, after rendering judgment, modified the penalty by
deleting certain damage awards and ultimately ordered reclusion perpetua in lieu of the death
penalty, while still affirming her conviction.
The case was elevated automatically to the Supreme Court for review due to the penalty
imposed.
Issue:
Sufficiency of Circumstantial Evidence
Whether the interlocking circumstantial evidence—such as the accused’s hurried departure,
nervous demeanor, and possession of a disposable lighter—was enough to establish her guilt
beyond a reasonable doubt.
Whether the combined testimonies of the barangay officials and witnesses reliably created an
unbroken chain of evidence implicating the accused.
Admissibility of Confessions and Hearsay
Whether the uncounselled extrajudicial confessions given by the accused to Barangay Chairman
Bernardo, Mercedita Mendoza, and in media interviews were admissible.
Whether the hearsay statements, particularly those relayed by SPO4 Danilo Talusan, should
have been excluded on constitutional grounds under Article III, Section 12(1) and (3).
Proper Characterization of the Crime
Whether charging the accused with “Arson with Multiple Homicide”—a descriptive caption
rather than a statutory formulation—was valid.
Whether the crime committed should be classified as simple arson absorbing the resultant
deaths or as a complex crime requiring a separate charge for homicide/murder.
Appropriate Penalty and Civil Liabilities
Whether the initial imposition of the death penalty was appropriate given the circumstances and
applicable laws.
The requirement to modify penalties and civil damage awards based on the classification of the
offense under Article 320 of the Revised Penal Code versus Section 5 of PD No. 1613.
