G.R. No. 175602 - People vs. Valdez

PO2 Eduardo Valdez and Edwin Valdez were charged with three counts of murder before RTC, Branch 86, Quezon City.
On January 20, 2005, the RTC convicted both, sentenced each to reclusion perpetua per count, and ordered damages of ₱93,000 actual, ₱50,000 civil indemnity, and ₱50,000 moral per victim.

On July 18, 2006, the CA affirmed the convictions but modified damages: ₱50,000 civil, ₱50,000 moral, ₱25,000 temperate, ₱25,000 exemplary per victim, plus costs.
Edwin withdrew his appeal on May 9, 2007; Eduardo’s appeal (G.R. No. 175602) proceeded to the Supreme Court.

On January 18, 2012, the SC modified Eduardo’s conviction to three counts of homicide, imposing indeterminate sentences of 10 years prision mayor to 17 years reclusion temporal, and reduced damages (₱50,000 civil, ₱50,000 moral, ₱25,000 temperate).
On March 12, 2012, Edwin wrote the Court Administrator invoking Section 11(a), Rule 122, requesting application of the SC’s favorable judgment to him; the Solicitor General filed no opposition on September 25, 2012.

Whether the informations sufficiently alleged treachery as an aggravating circumstance to sustain murder charges.
Whether the absence of factual averments on treachery warrants modification to homicide.

Whether Edwin—having withdrawn his appeal—may still benefit from the SC’s favorable modification under Section 11(a), Rule 122.
The scope and effect of appeals in cases involving multiple accused.