G.R. No. 202124 Title: People of the Philippines vs. Bernardino Gaffud, Jr.

Title: People of the Philippines vs. Ireneo Jugueta That on or about 8:00 o'clock in the evening of May 10, 1994
at Sitio Biton, Barangay Wasid, Municipality of Nagtipunan,
Facts: Province of Quirino, Philippines, and within the jurisdiction
 The case centers around Ireneo Jugueta, accused of of this Honorable Court, the above-named accused with
double murder and multiple attempted murders. - intent to kill and motivated by long... standing grudge, after
 On June 6, 2002, in Barangay Caridad Ilaya, Atimonan, conspiring, confederating and mutually helping one another,
Quezon, Jugueta allegedly: by means of fire, did then and there, willfully, unlawfully,
- Fatally shot Mary Grace Divina (13 years old) and feloniously,
and Claudine Divina (3 ½ years old). - shot and burn Manuel Salvador and Analyn Salvador which
- Attempted to murder the Divina family members caused their instantaneous death.
(Norberto Divina, Maricel Divina, Elizabeth
Divina, and Judy Ann Divina). It appears that Manuel Salvador and his daughter Analyn
. Salvador were killed when the house they were staying in
Issues: located at Sitio Biton, Barangay Wasid, Nagtipunan, Quirino
1. Whether Ireneo Jugueta’s identification by the main witness, was burned down while they were inside. An eyewitness
Norberto Divina, was credible and sufficient for conviction. pointed to accused-appellant Bernardino Gaffud, Jr. as one of
2. Whether the inconsistencies in Norberto Divina’s testimony
the arsonists.
affect his credibility.
he saw the house of his uncle burning. Because of the glow
3. Whether the principle of conspiracy was properly applied in
emanating therefrom, he saw three persons within the
determining Jugueta’s culpability.
vicinity of the burning house.
4. Clarification on the imposition of penalties for each count of
One of the three was holding a... flashlight, whom he
murder and attempted murder.
identified as appellant Gaffud, Jr. He could not identify the
5. The correct determination of damages due to the heirs of the
two other persons. Barangay Captain Potado Ballang testified
victims.
that he saw appellant Gaffud, Jr. on the fateful day at around

Court’s Decision: 6:30 PM, along the riverbank, a few meters away from the

The Supreme Court dismissed Jugueta’s appeal and affirmed the house of Manuel Salvador. When Potado asked what he was

CA’s decision with modifications. The Court held as follows for doing there, Gaffud, Jr. said he was looking for his boat.
each legal issue: However, Potado knew that the appellant did not own a boat.
1. **Credibility of Witness**: The Court found Norberto
Divina’s identification of Jugueta as credible, emphasizing the His defense of alibi was corroborated by his wife Juanita
deference given to the trial court’s assessment of witness Gaffud and in-law Balbino Bravo. Appellant denied the
credibility. accusation leveled against him, and testified that the
2. **Inconsistencies in Testimony**: The Supreme Court approximate time of the burning of the victims' house, he was
concluded that the minor inconsistencies in Norberto Divina’s at home, entertaining his in-laws, Balbino Bravo and Rufina
testimony were inconsequential and did not detract from his Bravo, who was there for a visit. After eating dinner, he and
overall credibility. Balbino Bravo... talked. At around 7:00 to 8:00 PM, he and
3. **Conspiracy**: The Court upheld the finding that Jugueta,
Balbino Bravo saw a blaze coming from the other side of the
together with two unidentified men, acted in conspiracy to
Cagayan River, about 50 to 80 meters away from the house
commit the crimes, as evidenced by their coordinated actions.
of the Bravos. They did not mind the blaze, and instead went
4. **Imposition of Penalties**: The Supreme Court clarified
to sleep.
the penalties, indicating Jugueta was guilty of two counts of
 Accused-appellant was near the place of the incident
murder and four counts of attempted murder, modifying the
just a few minutes before the crime was committed.
sentences according to the aggravating circumstance of dwelling
 Accused-appellant, together with two unidentified
and applicable jurisprudence.
persons, was near the house of the victims at the time it
5. **Determination of Damages**: The Court adjusted the
was on fire.
damages awarded to the victims’ heirs, setting specific amounts
for civil indemnity, moral damages, exemplary damages, and
temperate damages, including interest.
 Accused-appellant was in a hurry to leave the place of
the incident without giving any help to his kumpare
Manuel Salvador and the latter's daughter, Analyn. Orly
G.R. No. 168050:
 Salvador testified that he saw accused-appellant holding
a flashlight, in a hurry to leave the... burning house of There are two kinds of complex crime. The first is known as
the victim, going towards the direction of the river. compound crime, or when a single act constitutes two or
(iv) more grave or less grave felonies. The second is known as
Accused-appellant had a motive to kill the victims because complex crime proper, or when an offense is a necessary
of the complaint filed by Manuel Salvador's wife, Dominga means for committing the other.
Salvador, and the fact that he owed Manuel Salvador some
money. Dominga Salvador testified that she had filed a G.R. No. 174066
complaint against accused-appellant and... his brother in their PEOPLE OF THE PHILIPPINES, Plaintiff-
barangay for their act of slaughtering her pig. Aside from Appellee,vs.ERNESTO NARZABAL y CASTELO, JR.,
this, in the morning of the same fateful day, she went to the Accused-Appellant
house of accused-appellant aiming to collect her husband's
share in the profits for the construction of the barangay hall... Convicting accused Ernesto Narzabal of the crime of Rape
they had built, but the accused-appellant only told her that he with Homicide
and his in-law would see her husband later that day.
On June 26, 2002, accused Ernesto Narzabal, Jr. was
Issues: indicted for the special complex crime of Rape with
whether or not accused-appellant should be held liable for Homicidebefore the RTC. The Information reads:
two (2) separate counts of murder or for the complex crime That on or about the 2nd day of March 2002, at 10:00 o'clock
of double murder in the evening, more or less, in Purok 2, BarangaySta. Elena,
Municipality of Malinao, Province of Albay, Philippines, and
Ruling: within the jurisdiction of this HonorableCourt, the above-
IN VIEW WHEREOF, we hereby AFFIRM the March 31, named accused, with lewd design and by means of violence,
2005 decision of the CA in CA-G.R. CR-HC No. 00060 with force and intimidation, did then andthere wilfully, unlawfully
the following MODIFICATIONS: and feloniously have sexual intercourse with AAA,3 against
(1)... the penalty of death imposed on accused-appellant is her will and consent, and byreason and on the occasion
REDUCED to reclusion perpetua without eligibility for thereof, accused, with intent to kill, with treachery and taking
parole; advantage of superiorstrength, did then and there wilfully,
(2)... the civil indemnity for the death of the victims is unlawfully and feloniously assault, attack, strangle the neck
increased to P150,000, or P75,000 for each victim; and and bang the headof aforenamed AAA on the cemented
(3)... accused-appellant is ordered to pay exemplary damages floor, which caused her death, to the damage and prejudice of
in the amount of P50,000, or P25,000 for each victim. her legal heirs.

SO ORDERED. The cause of death was cardio-respiratory arrest by reason

Principles: of cerebral hemorrhage and skull fracture.
ARTICLE 48. Penalty for complex crimes. When a single
act constitutes two or more grave or less grave felonies, or  Had sexual intercourse with AAA against her will and
when an offense is a necessary means for committing the consent.
other, the penalty for the most serious crime shall be  Assaulted, strangled the neck, and banged the head of
imposed, the same to be applied in its... maximum period. AAA on the cemented floor, causing her death.
 Witnesses included AAA’s mother, barangay officials,
and the municipal health officer.

In a complex crime, although two or more crimes are actually

committed, they constitute only one crime in the eyes of the
law as well as in the conscience of the offender. Hence, there  The accused insisted that his intoxication at the time of
is only one penalty imposed for the commission of a complex the commission of the crime should have been
crime.
 consideredas a mitigating circumstance as it was proven
that he was a habitual drunkard. Under review is the conviction of Edmundo Villaflores for
 He denied having raped the victim asshown by Dr. rape with homicide by the Regional Trial Court
Bausa's explanation that there was no penetration (RTC),Branch 128, in Caloocan City based on circumstantial
because there was no complete laceration and thevictim evidence.
was still a virgin
 absence of spermatozoa did not disprove rapebecause That on or about the 2nd day of July, 1999 in Caloocan City,
the mere touching of the lips of the pudenda by the male Metro Manila, and within the jurisdiction of thisHonorable
organ was enough to consummate rape Court, the above-named accused with lewd design and by
 The victim sustained nineteen (19) injuries on the head, means of force, violence and intimidationemployed upon the
neck and different parts of her body, and afractured person of one Marita, a minor of five (5) years old, did then
skull as a result of the bashing of her head and there willfully, unlawfully andfeloniously lie and have
sexual intercourse with said Marita, against the latter’s will
The CA did not appreciate the intoxication of the accused as and without her consent, andthereafter with deliberate intent
a mitigating circumstance either because, under Article266-B to kill beat the minor and choked her with nylon cord which
of the Revised Penal Code, the crime of rape with homicide caused the latter’s death.
is punishable by death.
Facts:
Court’s Decision:  The case concerns the tragic death of a young girl
The accused is found guilty beyond reasonable doubt of the named Marita, aged four years and eight months
crime of rape with homicide.  Marita was found raped and murdered on July 2, 1999,
in Caloocan City, Philippines.
In a special complex crime of rape with homicide, the following  Her lifeless body was discovered in an abandoned house
elements must concur: near her residence.
(1) the accused had carnal knowledge of a woman;
 Witnesses Aldrin Bautista and Jovy Solidum implicated
(2) carnal knowledge of a woman was achieved by means of force,
Edmundo Villaflores in the crime.
threat or intimidation;and
 Villaflores was arrested and charged with rape with
(3) by reason or on occasion of such carnal knowledge by means of
force, threat or intimidation, the accused killed a woman.
homicide.
Legal Issues:
Penalty: Death.  Circumstantial Evidence: Whether circumstantial
Civil indemnity: Php100,000.00. evidence was sufficient to establish Villaflores’ guilt
Moral damages: Php50,000.00. beyond reasonable doubt.
 Composite Crime: The applicability and interpretation
of the “composite crime” of rape with homicide under
Philippine law.
 Penalty and Damages: The propriety of the penalty and
damages awarded by the lower courts.
Court’s Decision:
 The Supreme Court upheld Villaflores’ conviction
based on circumstantial evidence:
 Witness testimonies placed Villaflores with Marita on
the day she went missing.
 Marita’s body was found near Villaflores’ residence.

 Physical evidence linked Villaflores to the crime scene.

G.R. No. 184926:  Medical findings indicated rape and cause of death by
Title: People of the Philippines v. Edmundo Villaflores y strangulation.
Olano  Rape with homicide was treated as a unique, indivisible
offense.
 Penalty changed from death to reclusion perpetua (life  The applicability of Court of Appeals’ rulings in People
imprisonment) without parole eligibility. v. Diño and People v. Flores regarding frustrated theft in
 Damages awarded were modified to reflect the victim’s this case.
age.
Doctrine: Court’s Decision:
 Circumstantial evidence can conclusively prove guilt  The Supreme Court held that under the Revised Penal
beyond reasonable doubt. Code of the Philippines, the crime of theft is
 Rape with homicide is recognized as a composite crime, unsusceptible to the stage of frustration; it can only be
driven by a single criminal impulse. attempted or consummated.
 The determinative element, unlawful taking (or
Nature of rape with homicideas a composite crime, apoderamiento), was completed once Valenzuela
explained obtained possession of the items with intent to gain.
The felony of rape with homicide is a composite crime. A  Thus, irrespective of his ability or inability to freely
composite crime, also known as a special complex crime,is dispose of the items, the act constituted consummated
composed of two or more crimes that the law treats as a theft.
single indivisible and unique offense for being the product of  Appeals invoking the rulings from People v.
a single criminal impulse. It is a specific crime with a Diño and People v. Flores were rejected, as these did
specific penalty provided by law, and differs from not conclusively establish a legal basis for frustrated
acompound or complex crime under Article 48 of the theft under Philippine law.
Revised Penal Code,  Valenzuela’s petition was denied, reaffirming his
Article 48. Penalty for complex crimes. – When a single conviction for consummated theft.
act constitutes two or more grave or less grave felonies, or-
when an offense is a necessary means for committing the
other, the penalty for the most serious crime shall be convicted both petitioner and Calderon of the crime of
imposed, the same to be applied in its maximum period. consummated theft. They were sentenced to an in
determinate prison term of two (2) years of prison
correctional as minimum to seven (7) years of prison mayor
G.R. No. 160188: as maximum.17
Title: Aristotel Valenzuela Y Natividad vs. People of the
Philippines and Hon. Court of Appeals: Reexamining Doctrine:
Frustrated Theft in Philippine Jurisprudence  In the Philippine legal system, there is no intermediate
Facts: stage of frustrated theft according to the Revised Penal
 Aristotel Valenzuela and Jovy Calderon were charged Code.
with theft after being apprehended at a supermarket  Theft is considered consummated once there is
complex (Super Sale Club, within the ShoeMart deprivation of property through taking with the intent to
complex along North EDSA) for having stolen various gain, regardless of the offender’s subsequent ability to
cases of detergent on May 19, 1994. ‘freely dispose’ of the property taken
 Security guard Lorenzo Lago witnessed their activities,
which culminated in their failed escape.
 Both initially pleaded not guilty but later changed their
narrative, claiming they were mere bystanders during
the incident.

Legal Issues:
 Whether the theft committed by Valenzuela should be
considered as consummated or merely frustrated.
G.R. No. L-58886:
 Title: Consuelo E. Mallari vs. People of the Philippines This understanding of continuing crimes ensures that the
and Court of Appeals accused cannot be charged separately for each act within the
same criminal resolution. The constitutional guarantee
Facts: against double jeopardy prevents multiple prosecutions for
 Consuelo E. Mallari, along with three others, was the same or identical offense
accused of Estafa through Falsification of Public
Document. In this case, the acts in CA-G.R. No. 19849-CR were
 The charge stemmed from their fraudulent act of different and distinct from those in CA-G.R. No. 20817-CR,
offering Julia S. Saclolo the title of a land owned by constituting separate crimes.
Leonora Balderas as collateral when Saclolo needed
money.

Legal Issue:
 Whether Consuelo Mallari could be placed twice in
jeopardy for the same offense.
Court’s Decision:
 The Court ruled in favor of Consuelo Mallari, invoking
the constitutional guarantee against double jeopardy.
 Double jeopardy occurs when a person is charged with
an offense, and the case is terminated (acquittal or
conviction) without the accused’s consent.

Straight penalty of one (1) year, an indeterminate sentence

of four (4) months and one (1) day as minimum, to two (2)
years and four (4) months, asmaximum, was imposed on
petitioner.

In her motion for reconsideration, petitioner contended that

the decision in CA-G.R. No. 19849-CR placed her twice in
jeopardy of being punished for the same offense as she had
previously been convicted, sentenced and probationed for the
same offense in CA-G.R. No. 20817-CR entitled "People of
the Philippines versus Consuelo Mallari."

In the case of G.R. No. L-58886, the Supreme Court clarified

the concept of a continuing crime. Here’s what you need to
know:
 A continuing crime is a single offense that consists of a
series of acts arising from one criminal resolution.
 It involves a continuous, unlawful act or a sequence of
acts driven by a single impulse and operated by an
unintermittent force, regardless of how long it takes.
 Although there are multiple acts, legally, only one crime
is committed.
 Consequently, only one penalty is imposed for the entire
course of the offense.