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People v.

Malngan (2006)
G.R. No. 170470
Digest Author: Que
Doctrine: Constitutional guarantees no longer apply to confessions made to private individuals
during custodial investigation
Appellee: People of the Philippines
Appellant: Edna Malngan y Mayo

Facts:
1. Edna Malngan was a hired housemaid of Roberto Separa, Sr. She was seen hurriedly
leaving the house of her employer in Tondo, then boarded a pedicab.
2. Thirty minutes after Malngan was seen leaving, the Separa’s house was found to be on
fire.
3. An informant pointed at Malngan, so she was bought to the Barangay Hall for
investigation. A disposable lighter was later found in her bag.
4. Malngan confessed to the Barangay Chairman that she set her employer’s house on fire,
because she has not received her salary for one year, and because she wanted to go
home to her province, but her employer told her to ride a broomstick in going there.
5. Malngan was then turned over to arson investigators. Mendoza, her employer’s
neighbor and ABS-CBN led by Carmelita Valdez asked her why and how she burned
the house while she was in the detention cell. Malngan repeated the reason she gave the
Barangay Chairman and said that she set crumpled pieces of paper on fire and left them
on a table.
6. Talusan, one of the arson investigators heard Malngan’s confession in ABS-CBN news
through Carmelita Valdez and Gus Albelgas.
7. The fire resulted in the destruction of her employer’s house and other neighbors’ houses,
and the death of the employer and his family. Malngan was charged with arson with
multiple homicide. When arraigned, Malngan pleaded not guilty
8. Believing that there was no sufficient evidence to convict her, Malngan filed a demurrer
to evidence. The RTC held Malngan guilty and denied her demurrer to evidence. The
CA affirmed the RTC decision. The SC should automatically review the case because
death penalty is the punishment.

Issue:
W/N testimonies and evidence were admissible?

Held:
Yes, the testimonies and evidence were admissible.
1. Witnesses were disinterested persons who have no compelling reason to lie.
- There was more than one circumstance.
- The facts were proven.
- This combination produces conviction beyond reasonable doubt.
2. The Court relied on Malngan’s actuations (hurriedly left the house with head turning to
different directions, there was a disposable lighter in her bag, and her confessions to the
media) in resolving the case. These are circumstantial evidences in which facts in the
issue may be established by inference.
3. The confessions did not violate Malngan’s constitutional rights to remain silent and
against self-incrimination. While the rights apply to individuals under custodial
investigation (no longer a general inquiry, because they have pointed a specific suspect),
these constitutional guarantees do not apply when the suspect confesses to private
individuals. In this case, Mendoza and Carmelita Valdez.

Dispositive:
IN VIEW WHEREOF, the Decision of th e Court of Appeals dated 2 September
2005, in CA G.R. CR HC No. 01139, is hereby AFFIRMED insofar as the
conviction of accused -appellant EDNA MALNGAN Y MAYO is concerned. The
sentence to be imposed and the amount of damages to be awarded, however,
are MODIFIED. In accordance with Sec. 5 of Presiden tial Decree No. 1613,
accused-appellant is hereby sentenced to RECLUSION PERPETUA. Accused-
appellant is hereby ordered to pay the h eirs of each of the victims P50,000.00 as
civil indemnity.