G.R. No. L-11813 - People vs. Santos

Ten separate informations were filed before the Court of First Instance of Pangasinan charging defendants with the complex crime of rebellion accompanied by additional offenses such as multiple murders, robberies, arson, and physical injuries.
One of these cases, Information No. 20379, specifically charged several named individuals under various aliases, including Jaime Santos, alias “La Perla”/“Velasco”/“Santos”, along with others.
The indictment in this case alleged that from August 1947 to November 1953, the accused conspired as part of the Hukbong Magpapalaya Ng Bayan (HMB), more commonly known as the Hukbalahap or HUKS, to overthrow the Government of the Republic of the Philippines by force, involving an array of weaponry and engaging in politically motivated acts of violence.

The indictment detailed a series of incidents committed on different dates and in various municipalities within Pangasinan (and in one instance, Tarlac), including:

The November 15, 1950, raid in Mangatarem, Pangasinan where town government buildings were attacked, numerous civilians were killed or wounded, and private houses were burned.
The May 1, 1950, incident in Aguilar, Pangasinan involving robbery in band, arson, and the murder of an individual named Liberate Fernandez.
The December 2, 1951, raid in Infanta, Pangasinan involving an armed raid with the burning of a part of the town and the looting of firearms.
The February 29, 1952 (with evidence also regarding February 12, 1952) raid in Urbiztondo, Pangasinan where government forces were attacked in furtherance of the insurrectionary aims of the group.
Additional incidents included armed confrontations in Mabini, Tarlac and another series of killings and robberies in the Magdalena mountains and in the Barrio of Pogonsili, Aguilar, Pangasinan.

The charges were couched such that rebellion was complexed with other common crimes, leading to a multiplicity of offenses being attributed to the accused within the single information.

Out of the several accused, only Jaime Santos and Luciano Figueroa were apprehended, while others were at large.
Jaime Santos moved to quash the information on the ground that it accuses him of multiple offenses (i.e., simple rebellion along with unrelated common crimes) in violation of procedural rules regarding multiplicity of charges.
During the trial, three defendants in the same information pleaded guilty to the crime of simple rebellion after a revision of the charges against them by the Fiscal.
The trial court eventually proceeded with the joint trial of Jaime Santos and Luciano Figueroa based on an agreement between the prosecution and the defendants.

The trial judge rendered a judgment against Jaime Santos finding him guilty beyond reasonable doubt of the complex crime of rebellion with multiple murder, arson, and robbery.
Santos was sentenced to suffer the penalty of reclusión perpetua (life imprisonment) along with accessory penalties, indemnification payments for victims’ families, and the payment of proportional costs.
In contrast, Luciano Figueroa was found innocent of the complex charge of rebellion but was convicted of illegal association under Article 147 of the Revised Penal Code and sentenced to arresto mayor.
The case of the remaining accused was provisionally dismissed on the ground that they were still at large.

Only Jaime Santos appealed the decision, arguing that the lower court erred in sentencing him to life imprisonment rather than a lesser penalty (specifically, 1 year, 1 month, and 10 days of correctional imprisonment).
Santos also contended that his conviction for the complex crime of rebellion with additional offenses should not have been sustained given established doctrines from People vs. Hernandez and People vs. Geronimo.
The central factual controversy revolved around whether the acts committed during the various raids should be considered independent common crimes or be absorbed by the crime of rebellion.

Whether the crime of rebellion, when accompanied by acts such as murder, arson, and robbery, forms a complex crime or if these additional offenses should be treated as separate and independent acts punishable under common crime statutes.
Whether the inclusion of multiple common crimes in the same information against the appellant constitutes a violation of procedural rules on multiplicity of offense charges (specifically with reference to Section 12, Rule 106 of the Rules of Court and Section 2-(e) of Rule 113).
Whether the trial court’s imposition of the penalty of reclusión perpetua against Jaime Santos, without considering his plea and the mitigating circumstances, was in error in light of the doctrines established in People vs. Hernandez and People vs. Geronimo.