Case Digest (G.R. No. 131588)
Facts:
The case is People of the Philippines v. Glenn de los Santos, G.R. No. 131588, March 27, 2001, the Supreme Court En Banc, Davide Jr., C.J., writing for the Court. The plaintiff-appellee is People of the Philippines; the accused-appellant is Glenn de los Santos (GLENN), charged in the Regional Trial Court (RTC), Branch 38, Cagayan de Oro City.On October 5, 1995, during an early-morning "endurance run" of trainees of the Special Counter Insurgency Operation Unit, an Isuzu Elf truck struck and killed twelve trainees and injured many others. GLENN surrendered to local authorities and was charged by information with Multiple Murder, Multiple Frustrated Murder and Multiple Attempted Murder under Article 248 in relation to Article 6 of the Revised Penal Code. The prosecution presented eyewitness testimony describing rear guards signaling vehicles to move left and the truck approaching at high speed with high-beam lights; an ocular inspection and police measurements found broken windshield, heavy front damage and a 70-foot trail of blood with no visible skid marks. The defense presented GLENN’s account: an overnight trip to fetch band members, consumption of three bottles of beer, poor and foggy lighting conditions, temporary blindness from an oncoming vehicle’s bright headlights, and that the impacts occurred suddenly and he did not appreciate what he had hit until later; GLENN surrendered later the same day.
At trial the court conducted ocular inspections, received testimony regarding weather (PAG-ASA witness), neighbor rebuttal testimony, and evidence about the truck’s damage. On August 26, 1997, the RTC convicted GLENN of the complex crime charged and sentenced him to death, with indemnities ordered. Because the death penalty was imposed, the case came to the Supreme Court by automatic review. GLENN contested the RTC’s findings that he acted with deliberate intent to kill and persisted in accelerating after the first impacts; he argued the event was accidental or due to momentary incapac...(Pro-only)
Issues:
- Did the prosecution prove that GLENN acted with deliberate intent to kill such that he could be convicted of multiple murder, frustrated murder and attempted murder?
- If not intentional, did GLENN’s conduct constitute reckless imprudence resulting in multiple homicide and other injuries, and how should the crimes be characterized and punished (including the application of Article 48 and the Indeterminate Sentence Law)?
- Did GLENN’s failure to render assistance at the scene qualify as a circumstance that increases the penalty under Article 365?
- Should the tri...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)