PLURALITY

OF CRIMES
UNDER ARTICLE 48 OF THE REVISE PENAL CODE
WHAT IS PLURALITY?

FLOWER
WHAT IS PLURALITY?

FLOWERS
WHAT IS PLURALITY?
 PLURALITY
• It is provided in Article 48 of our Revised Penal Code that when
a single 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 imposed,
the same to be applied in its maximum period. The intention of
the Code in installing this particular provision is to regulate the
two cases of concurrence or plurality of crimes which in the
field of legal doctrine are called "real plurality" and "ideal
plurality".
 PLURALITY OF CRIMES
• "Ideal plurality" or "concurso ideal" occurs when a single act gives rise
to various infractions of law. This is illustrated by the very article under
consideration: (a) when a single act constitutes two or more grave or less
grave felonies (described as "delito compuesto" or compound crime);
and (b) when an offense is a necessary means for committing another
offense (described as "delito complejo" or complex proper). "Real
plurality" or "concurso real", on the other hand,arises when the accused
performs an act or different acts with distinct purposes and resulting in
different crimes which are juridically independent. Unlike "ideal
plurality", this "real plurality" is not governed byArticle 48
 PLURALITY OF CRIMES

• single act constitutes • when an offense is a

two or more grave or necessary means for
less grave felonies committing the other
PLURALITY OF CRIMES
CLASSIFICATION OF PLURALITY OF
CRIMES
• FORMAL/ IDEAL PLURALITY
• REAL/MATERIAL PLURALITY
KINDS FORMAL/ IDEAL PLURALITY
• Complex crime;
• Special complex crimes (Composite
crime); and
• Continued crimes.
FORMAL/IDEAL PLURALITY
Ideal plurality occurs when a single act gives rise to
various infractions of law. This is illustrated by
Article 48 of the Revised Penal Code which states:
(a) when a single act constitutes two or more grave
or less grave felonies (compound crime); and (b)
when an offense is a necessary means for
committing another offense (complex proper)
REAL/MATERIAL PLURALITY.
Real plurality arises when the accused performs an
act or different acts with distinct purposes and
resulting in different crimes which are juridically
independent.
GAMBOA V. COURT OF APPEALS, G.R. NO.
L-41054, NOVEMBER 28, 1975
• The City Fiscal of Manila filed seventy-five cases of estafa against Benjamin Lu Hayco
for defalcations committed from October 2, 1972, to December 30, 1972.
• The accusations stated that, as an employee, Hayco collected money from his employer’s
customers,under the obligation to account for and deliver the collection, but instead
misappropriated and converted it for personal use by depositing it in his account and
withdrawing the same.
• The lower court dismissed Hayco’s petition for prohibition, claiming that all the
indictments were components of one crime. However, the appellate court reversed the
order, directing the City Fiscal to consolidate the charges in one information and file it
with the proper court.
Issues:
• Whether the acts of Hayco constitute a single crime of estafa.
• Whether the City Fiscal acted properly in filing separate informations for each day of
abstraction.

Ruling:
The Supreme Court reversed the appellate court’s decision, holding that the City Fiscal acted
properly.

Each day of conversion constitutes a single act with an independent existence and criminal
intent.

The abstractions occurred on various dates, and each conversion is a complete act. The
similarity of the pattern does not affect the susceptibility of the acts to divisible crimes.
**Connection to the Lesson:**
It clarifies that, in estafa cases, each act of misappropriation can be considered an
independent offense if committed on different occasions. The ruling emphasizes the
importance of examining the singularity of criminal acts and intent to determine whether
they constitute a complex crime or multiple offenses.

REAL PLURALITY
IVLER V. MODESTO-SAN PEDRO
Facts:
• -Jason Ivler (petitioner) faced charges in the Metropolitan Trial Court of
Pasig City for two separate offenses stemming from a vehicular collision in
August 2004: (1) Reckless Imprudence Resulting in Slight Physical Injuries
(Criminal Case No. 82367) and (2) Reckless Imprudence Resulting in
Homicide and Damage to Property (Criminal Case No. 82366).
• On September 7, 2004, Ivler pleaded guilty to the charge in Criminal Case
No. 82367 and received the penalty of public censure.
• -Invoking his conviction in Criminal Case No. 82367, Ivler moved to quash
the Information in Criminal Case No. 82366, arguing that it subjected him
to double jeopardy.
-
IVLER V. MODESTO-SAN PEDRO
- The Metropolitan Trial Court (MeTC) refused to quash, finding no identity of
offenses in the two cases.
- Ivler elevated the matter to the Regional Trial Court of Pasig City (RTC)
through a petition for certiorari (S.C.A. No. 2803).
- While the petition was pending, Ivler sought the suspension of proceedings in
Criminal Case No. 82366, but the MeTC proceeded with arraignment, leading
to the cancellation of Ivler's bail and an order for his arrest.

- The RTC, without delving into the merits, dismissed S.C.A. No. 2803, citing
Ivler's loss of standing due to the MeTC's arrest order.
Issues:
- Whether the RTC erred in dismissing S.C.A. No. 2803 based on Ivler's loss of
standing.
- Whether the Double Jeopardy Clause applies to bar a second prosecution for
Reckless Imprudence Resulting in Homicide and Damage to Property after Ivler's
conviction for Reckless Imprudence Resulting in Slight Physical Injuries.
Ruling:
- The RTC erred in dismissing S.C.A. No. 2803 based on Ivler's loss of standing,
as the dismissal was not rooted in the merits of the case.
- The case raises the issue of whether the Double Jeopardy Clause applies, and the
ruling does not provide a resolution on this matter.
- A reconsideration sought by Ivler proved unavailing.
Connection to the Lesson:

The case of Ivler v. Modesto-San Pedro highlights the application of the Double Jeopardy
Clause in the context of charges stemming from a single incident. The rejection of the
petitioner's argument and the dismissal based on loss of standing underscore the complexities
in determining the identity of offenses and the subsequent implications for double jeopardy.
This case provides insight into the real and ideal plurality of crimes under the Revised Penal
Code, emphasizing the importance of analyzing the mental attitude behind the act rather than
merely focusing on the act itself.

IDEAL PLURALITY
CASE DIGEST: MONTEVERDE V. PEOPLE
Facts:
• Petitioner Monteverde was charged with the complex crime of estafa
through falsification of a commercial document.
• The Sandiganbayan found Monteverde guilty of falsification despite
acquittal for estafa.
• The issues raised included the nature of complex crimes, the
classification of a sales invoice as a public or commercial document,
and the proof of guilt for falsification.
-
Issue:
• Whether the acts attributed to the petitioner constitute a complex
crime.
• Whether the sales invoice in question is a commercial or public
document.
• Whether the prosecution proved the guilt of the petitioner beyond
a reasonable doubt for the crime of falsification.
Ruling:
• The court held that the acts attributed to the petitioner did not constitute a
complex crime. Falsification was not a necessary means for committing
estafa, and the two crimes were not the result of a single act.
• The Sales Invoice was considered both a public and commercial document,
meeting the criteria under the Revised Penal Code. It became part of official
records and was intended for public consumption.
• The court ruled in favor of the petitioner, stating that the prosecution failed to
prove beyond reasonable doubt the guilt for falsification. There were material
differences between the presented documents, and the prosecution did not
establish that the sales invoice was falsified.
Connection to the Lesson:

• The case highlights the distinction between real and ideal plurality of
crimes under the Revised Penal Code.
• The Sandiganbayan initially treated the case as a complex crime, but the
Supreme Court clarified that the acts did not meet the criteria for a complex
crime.
• The lesson on real plurality involves a single act resulting in multiple
offenses, while ideal plurality involves a single criminal act constituting
two or more grave or less grave felonies.
Connection to the Lesson:

• The court emphasized the importance of correctly charging offenses in an

information and the need for the prosecution to prove each element of the
crimes charged.
• This case illustrates the application of the principles of real and ideal
plurality of crimes in the context of a complex crime charge, emphasizing
the significance of accurate legal classification and the burden of proof in
criminal cases.

REAL PLURALITY
CASE DIGEST: PEOPLE V. GAFFUD, JR.
• Accused-appellant Bernardino Gaffud, Jr. was found guilty of two (2)
counts of murder for killing Manuel Salvador and Analyn Salvador by
means of fire. Evidence for the prosecution presented the following:

• 1) That on the night of May 10, 1994, Orly Salvador, while on his way to
the house of his uncle Manuel Salvador, heard two gunshots and thereafter
saw the house of his uncle burning. He saw three persons within the
vicinity of the burning house, one of whom he identified as appellant
Gaffud, Jr.
-
CASE DIGEST: PEOPLE V. GAFFUD, JR.
2) That Dan Dangpal, neighbor of the deceased, at about 8:00 PM that evening, heard successive
gunshots and saw the deceased’s house burning.

3) That prior the incident, Barangay Captain Potado Ballang saw the appellant a few meters away
from the house of the deceased.That prior the incident, Barangay Captain Potado Ballang saw the
appellant a few meters away from the house of the deceased.

4) That earlier that day, Dominga Salvador, common-law wife of Manuel Salvador and mother of
Analyn Salvador, went to the house of the appellant to inquire about her husband’s share in the
construction of the barangay hall. Dominga also related that had earlier filed a complaint against
the appellant and his brother for slaughtering her pig.
Issue:
• 1) Whether or not there was conspiracy.
• 2) Whether or not accused-appellant should be held liable for two
(2) separate counts of murder or for the complex crime of double
murder.
Ruling:

• 1) The necessity of proving conspiracy is emphasized, but in the specific

case, direct evidence already establishes the accused's participation in the
crime. Therefore, proving conspiracy is no longer essential for the
conviction.

• 2) The court ruled that in the commission of a complex crime, where

multiple offenses occur with a single objective, they are considered as one
crime both legally and morally. In this particular case, the burning of a
house with the intent to kill resulted in the complex crime of double
murder, leading to the imposition of a single penalty.
Connection to the Lesson:

• The court's emphasis on the direct participation of Gaffud, Jr. in the killing
of the victims without the need to prove conspiracy aligns with the
principles of real plurality, where separate and distinct acts result in
separate crimes.
• The decision highlights the importance of considering the circumstances
and the offender's intent in determining whether a complex crime exists.

IDEAL PLURALITY
Single criminal impulse doctrine
The single impulse rule in criminal law
refers to the idea that a crime can only be
committed with one intent or purpose. This
means that the defendant cannot be
accused of multiple crimes based on a
single act or omission.
Complex crime
Article 48. Penalty for complex crimes. - When a single 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 imposed, the same to be applied in its maximum
period.
The underlying philosophy of complex crimes in the Revised Penal
Code, which follows the pro reo principle, is intended to favor the
accused by imposing a single penalty irrespective of the crimes
committed. The rationale being, that the accused who commits two
crimes with single criminal impulse demonstrates lesser perversity
than when the crimes are committed by different acts and several
criminal resolutions.
The legislature crafted this procedural tool to benefit the accused
who, in lieu of serving multiple penalties, will only serve the
maximum of the penalty for the most serious crime.
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 is only one penalty imposed
for the commission of a complex crime .
Compound Crime
There is a compound crime when a single act
constitutes two or more grave or less grave
felonies.
The classic example of the first of kind is when a single
bullet results in the death of two or more persons, or the
single act of throwing a grenade resulting in the death of
another person and injuring four others produced the
complex crime of murder and multiple attempted murders.
The single act of burning the house of the victim,
with the main objective of killing the latter and his
daughter, resulting in their deaths resulted the single
act of accused in the complex crime of double
murder.
The single act by accused of detonating a hand grenade may
quantitatively constitute a cluster of several separate and distinct
offenses, yet these component criminal offenses should be considered
only as a single crime in law on which a single penalty is imposed
because the offender was impelled by a single criminal impulse which
shows his lesser degree of perversity.
JURISPRUDENCE
People v. Guillen (G.R. No. L-1477)
FACTS:
On March 10, 1947, in an event sponsored by the Liberal Party at Plaza Miranda in
Quiapo, Manila, Guillen planted a hand grenade near the stage and threw another one
toward then President Manuel Roxas in an apparent assassination attempt born out of
Guillen's spite for the President over the latter's perceived failure to fulfill his promises
and his call for the passage of the so-called parity measure. General Castaneda managed
to kick the grenade off the stage. However, its explosion caused the death of Simeon
Varela (Barrela). It also caused the injuries of Alfredo Eva, Jose Fabio, Pedro Carillo, and
Emilio Maglalang.
Guillen pleaded not guilty to the consequent charges of murder and multiple frustrated
murder filed against him. At one point, he even tried to use the insanity excuse, but he was
found to have been mentally stable.

Later on, by his own admission, he confessed to his crimes. He was subsequently found
guilty of all the charges and was sentenced to death.

ISSUE:

Whether or not the conviction of the accused was proper.

HELD:
No, the SC ruled that Guillen's actions on March 10, 1947 and their penalties
were covered by Art. 48 of the RPC, not sub-section 1 of Art. 49. The Court said
that by a single act -- throwing a hand grenade at President Roxas -- he
committed two grave felonies:
(a) murder and (b) multiple attempted murder.

The Court ruled that the injuries sustained by the other victims constitute
attempted and not frustrated murder. The Court reasoned that Guillen's failed
attempt to kill President Roxas was due to some reason or accident (General
kicking the grenade off the stage) other than his own spontaneous desistance.
PEOPLE v. ANTONIO COMADRE
Facts:
Appellants Antonio Comadre, George Comadre and Danilo Lozano were charged with
Murder with Multiple Frustrated Murder... at around 7:00 in the evening of August 6,
1995, Robert Agbanlog, Jimmy Wabe, Gerry Bullanday,... Rey Camat and Lorenzo
Eugenio were having a drinking spree on the terrace of the house of Robert's father,
Barangay Councilman
Jaime Agbanlog, situated in Barangay San Pedro, Lupao, Nueva Ecija.
PEOPLE v. ANTONIO COMADRE
Facts:
As the drinking session went on, Robert and the others noticed appellants Antonio
Comadre, George Comadre and Danilo Lozano walking. The three stopped in front of the
house. While his companions looked on, Antonio suddenly lobbed an object which fell on
the roof of the terrace.
The object, which turned out to be a hand grenade, exploded ripping a
hole in the roof of the house. Robert Agbanlog, Jimmy Wabe, Gerry
Bullanday, Rey Camat and Lorenzo Eugenio were hit by shrapnel and
slumped unconscious on the floor.

After trial, the court a quo gave credence to the prosecution's evidence
and convicted appellants of the complex crime of Murder with
Multiple Attempted Murder
Issues:
Whether or not the appellants are guilty of a complex (compound)
crime.
Ruling:
The single act by appellant of detonating a hand grenade may
quantitatively constitute a cluster of several separate and distinct
offenses, yet these component criminal offenses should be considered
only as a single crime in law on which a single penalty is imposed
because the... offender was impelled by a "single criminal impulse"
which shows his lesser degree of perversity.
People vs. Carpo, et al
Facts
On the evening of August 25, 1996, a hand grenade explosion occurred at
Florentino Dulay's house, resulting in the deaths of Florentino, his daughter
Norwela, and a five-year-old child named Nissan. Another daughter, Noemi,
survived but sustained injuries. Ruben Meriales testified that he saw Jaime Carpo
and others near the crime scene, with one of them hurling the grenade into the
house. The trial court convicted Carpo and the other accused of multiple murder
and attempted murder based on Ruben's testimony.
People vs. Carpo, et al
Issues:
1. Whether the results of the lie detector test should be admitted as evidence.
2. Whether the trial court correctly convicted the accused of multiple murder
complexed with attempted murder.
People vs. Carpo, et al
**Ruling:**

**Issue 1: Admissibility of Lie Detector Test Results**

The court rejected the admission of lie detector test results, asserting that such tests
lack acceptance in the scientific community for determining truth or deception.

**Issue 2: Conviction of Multiple Murder Complexed with Attempted Murder**

The court affirmed the trial court's ruling that the accused conspired to commit the
crime. Despite the possibility of labeling the crime as murder qualified by explosion,
the court adhered to the charge of murder with treachery, as stated in the information.
The resulting crimes were considered multiple murder complexed with attempted
murder, arising from a single act—the grenade explosion.
The court applied Article 48 of the Revised Penal Code, which stipulates that the penalty for the
more serious crime (in this case, reclusion perpetua to death) should be imposed in its maximum
period. The death penalty was upheld by the court due to the complex nature of the crimes
committed by the accused.

**Connection to the Lesson (Compound or Complex Crime):**

The case highlights the application of the principle of compound or complex crimes under Article 48
of the Revised Penal Code. The court considered the multiple murder and attempted murder as a
compound crime resulting from a single act—the explosion caused by the hurling of a grenade into
the victims' residence. The lesson underscores that when multiple offenses arise from a single
criminal act, the court must apply the penalty for the most serious crime in its maximum period. In
this case, the death penalty was imposed due to the gravity and complexity of the offenses committed
by the accused.
People v. Nelmida
Facts: On June 5, 2001, appellants Wenceslao Nelmida and Jovito C. Tomaneng
ambushed a convoy in a manner that resulted in the death of two victims and injuries to
several others. The victims included Macasuba Tandayao, Mosanip Ameril, PFC Gapor
Tomanto, PFC Haron Angni, and Juanito Ibunalo. The trial court found the appellants
guilty of two counts of murder and seven counts of attempted murder. Appellants were
sentenced to reclusion perpetua for murder and an indeterminate penalty for attempted
murder.
Issues:
Whether the acts committed by the appellants constitute two separate and
distinct crimes (murder and attempted murder).

How should the penalties be applied considering the circumstances of

the case?
Ruling:

The Supreme Court affirmed the trial court's finding that appellants
committed two separate and distinct crimes – murder and attempted
murder. The appellants were found guilty beyond reasonable doubt of
two counts of murder for the deaths and seven counts of attempted
murder for the injuries.
The Court applied the rules on the graduation of penalties. The penalty
for murder, reclusion perpetua to death, was reduced by two degrees,
resulting in reclusion perpetua. For attempted murder, the
indeterminate penalty of 4 years and 2 months of prision correccional,
as a minimum, to 10 years of prision mayor, as a maximum, was
imposed. Additionally, the court awarded civil indemnity, moral
damages, exemplary damages, and temperate damages to the victims
and their heirs.
Case Digest: People v. Sanchez
Facts:
On April 13, 1991, in Calauan, Laguna, Nelson Peñalosa, a political
leader, was ambushed and killed by a group of individuals allegedly
acting on the orders of Mayor Antonio L. Sanchez. The assailants,
including Sanchez and Artemio Averion, were accused of conspiring to
commit the murders. The prosecution presented witness Malabanan, a co-
conspirator, who detailed the planning, preparation, and execution of the
crime. The trial court found the accused guilty of double murder and
sentenced them to reclusion perpetua.
Issues:
1. Whether the act of shooting the victims using armalites in automatic
firing mode constitutes a single act or multiple acts.
2. Whether the accused should be held liable for a complex crime of
double murder.
3. Whether the aggravating circumstances of evident premeditation,
nighttime, and use of a motor vehicle are present.
Ruling:
1. The act of shooting the victims using armalites in automatic firing mode constitutes
multiple acts. The accused fired three bursts of gunfire, and each burst produced several
bullets, leading to multiple offenses.
2. The accused are not liable for a complex crime of double murder. Instead, they are
criminally liable for two counts of murder, one for each victim.
3. The aggravating circumstance of evident premeditation is present. The accused planned
the killing as early as 10:00 in the morning and even looked for weapons and a vehicle for
the operation. The aggravating circumstance of use of a motor vehicle is also appreciated.
The court ruled that the act of shooting the victims, even though stemming from a single
act of pressing the trigger, should be considered multiple acts due to the number of bullets
fired. The accused were held liable for two counts of murder instead of a complex crime
of double murder. This decision aligns with the legal principle that when a single act
results in multiple offenses, the penalty for the more serious crime in its maximum period
shall be imposed.

In summary, the case underscores the importance of accurately characterizing criminal

acts and applying the appropriate legal principles, especially when determining whether
offenses should be treated as a compound or complex crime.
People v. Adriano y Samson
**Facts:**
On March 13, 2007, in Malapit, San Isidro, Nueva Ecija, accused Rolly Adriano y Samson, along
with unidentified accomplices, ambushed a vehicle, resulting in the deaths of Danilo Cabiedes and
Ofelia Bulanan. Adriano was charged with two counts of Murder for the killings. The prosecution's
version asserts that Adriano was positively identified as one of the assailants who shot Cabiedes,
while a stray bullet from the same attack killed Bulanan.

**Issues:**
1. Whether the killings of Cabiedes and Bulanan constitute a compound or complex crime.
2. Whether the aggravating circumstance of treachery can be appreciated in the death of Bulanan.
Ruling
1. The killings of Cabiedes and Bulanan do not constitute a compound or complex crime.
The court ruled that the acts resulted in two separate and distinct crimes of murder rather
than a single compound crime. The doctrine in People v. Nelmida was applied,
emphasizing that when various victims expire from separate shots, such acts constitute
separate and distinct crimes.

2. Treachery can be appreciated in the death of Bulanan. Despite Bulanan's death being a
result of a stray bullet, the court followed the precedent in People v. Flora, where it was
ruled that treachery may be appreciated in aberratio ictus. The presence of treachery in the
killing of Cabiedes also applies to Bulanan, as both victims were defenseless during the
orchestrated ambush.
Connection to the Lesson

The court clarified that the deaths of Cabiedes and Bulanan,

although stemming from the same criminal act, constitute
separate and distinct crimes of murder due to the individual
nature of the fatal shots. The decision aligns with the doctrine in
People v. Nelmida, emphasizing the importance of examining the
nature of the acts and their effect on the victims to determine
whether a compound or complex crime exists.
People v. Flora Brothers
Facts:
1.Charges:The accused, Hermogenes Flora and Edwin Flora, were charged with the
crimes of double murder and attempted murder.
2.Incident:On January 10, 1993, at around 1:30 a.m., in Sitio Silab, Barangay Longos,
municipality of Kalayaan, Laguna, the accused, armed with a caliber .38 handgun,
attacked and shot three victims during a dance party.
3. Victims:
- Emerita Roma: Fatally shot and died immediately.
- Ireneo Gallarte: Fatally shot and died immediately.
- Flor Espinas: Injured but survived due to timely medical attention.
4. Legal Basis: The accused were charged with murder, qualified by treachery, for the
deaths of Emerita Roma and Ireneo Gallarte. Hermogenes Flora was additionally
charged with attempted murder for the injuries inflicted on Flor Espinas.
Issues:
• Whether the prosecution established the identity and guilt of the
accused beyond reasonable doubt.
• Whether there was a conspiracy between the accused, particularly
in the context of the murders and attempted murder.
**Ruling:**
The trial court found both accused guilty beyond reasonable doubt of double murder for
the deaths of Emerita Roma and Ireneo Gallarte. Hermogenes Flora was also found guilty
of attempted murder for the injuries to Flor Espinas. The court rejected the defense of alibi
presented by the accused, emphasizing their active participation in the crimes.

The court recognized a conspiracy between the accused, particularly highlighting Edwin
Flora's active participation and cooperation with Hermogenes Flora in the commission of
the crimes.
**Connection to the Lesson (Compound or Complex Crime):**
- The case involves a compound crime where multiple criminal acts were committed in a
single incident: double murder (for the deaths of Emerita Roma and Ireneo Gallarte) and
attempted murder (for the injuries to Flor Espinas).
- The court's recognition of a conspiracy between the accused underscores the
interconnectedness of their actions in executing the criminal acts. Conspiracy plays a
crucial role in determining the liability of each accused for the various offenses committed
during the incident.
- Understanding the concept of compound crimes, as illustrated in this case, is essential in
criminal law. It involves analyzing the relationships between different offenses committed
in a single act, and the court's decision provides a practical application of legal principles
related to compound crimes.
People of the Philippines v. Martin Alagao, et al.
Facts:
- On October 20, 1962, the City Fiscal of Manila filed an information against the
defendants, members of the Manila Police Department, charging them with the complex
crime of incriminatory machinations through unlawful arrest.
- The accusation stemmed from the defendants' alleged act of unlawfully arresting Marcial
Apolonio y Santos, a Local Civil Registrar's Office employee, for bribery and
subsequently planting marked money on him during the investigation.
Issues:
1. Whether the information alleges a complex crime of incriminatory machinations through unlawful
arrest.
2. Whether the court has jurisdiction to try the accused for the offenses charged.

**Ruling:**
- The trial court sustained the motion to quash, holding that the information did not allege a complex
crime. It reasoned that the alleged planting of evidence occurred after the victim's arrest, making the
offenses independent.
- The Supreme Court reversed the decision, stating that the information sufficiently alleged a
complex crime because the unlawful arrest was a necessary means to commit incriminatory
machinations.
- The court also affirmed the jurisdiction of the Court of First Instance over the offenses, considering
that both unlawful arrest and incriminatory machinations are punishable by arresto mayor.
**Connection to the Lesson (Compound or Complex Crime):**
- In this case, the concept of a complex crime is discussed. The court clarified that for an
information to charge a complex crime, it is enough that the allegations show one offense
as a necessary means to commit the other, even if the legal definitions of the crimes do not
align.

- The ruling emphasizes the importance of examining the facts alleged in the information
to determine whether the offenses are independent or constitute a complex crime.
People v. Sabadlab y Bayquel

Facts:
Erland Sabadlab y Bayquel (Sabadlab) was convicted by the Regional Trial Court (RTC)
for forcible abduction with rape. The victim, AAA, a 16-year-old domestic helper, was
forcibly abducted, blindfolded, and raped by Sabadlab and two other men. AAA positively
identified Sabadlab as one of the perpetrators. Medical evidence supported AAA's
account, showing physical injuries and signs of recent loss of virginity. Sabadlab denied
the charges, asserting an alibi defense, claiming he was elsewhere during the incident.
Both the RTC and the Court of Appeals (CA) found AAA's testimony credible and
convicted Sabadlab.
People v. Sabadlab y Bayquel

**Issues:**
1. Whether the inconsistencies in AAA's testimony affected her overall credibility.
2. Whether the crime committed was forcible abduction with rape or simple rape.
3. Whether Sabadlab's alibi defense was sufficient to rebut the charges.
**Ruling:**
1. The court affirmed the credibility of AAA's testimony, noting that minor inconsistencies
did not undermine the substance of her declaration. Both the RTC and CA found her to be
a credible witness.

2. The court clarified that the crime committed was simple rape, not forcible abduction
with rape. The court explained that when the objective of abduction is to commit rape, the
rape absorbs the forcible abduction. The penalty of reclusion perpetua was upheld.

3. Sabadlab's alibi defense was rejected as both lower courts found AAA's positive
identification more credible. The court affirmed Sabadlab's conviction based on the
evidence presented during the trial.
People v. Sabadlab y Bayquel
Connection to the Lesson :

The case involves a discussion of the compound or complex crime. The court
clarified that in situations where the objective of abduction is to commit another
crime, such as rape, the latter absorbs the former. This distinction is crucial in
understanding the legal classification and penalty imposition for offenses that
occur in a sequential manner and are closely connected.