Case Summary (G.R. No. L-23771)
Factual Background
The charges against the respondents arose from a singular incident where multiple shots were fired into the Mendoza household, resulting in the death of Teofilo Mendoza and minors Neceforo Mendoza, Epifania Mendoza, and Marcelo Mendoza, and the wounding of Valeriana Bontilao de Mendoza. The City Fiscal initially filed five separate informations against the defendants, citing distinct acts leading to murder and frustrated murder.
Orders of the Respondent Judge
On May 13 and May 31, 1966, the respondent Judge issued orders consolidating the five cases into one, reasoning that the incidents stemmed from a single impulse. The Judge's position suggested consolidating the charges would prevent the need to try five individual cases, which he viewed as a time-saving measure.
Petition for Certiorari
In response, the People filed a petition for certiorari against the respondent Judge's orders, arguing that such consolidation was issued without jurisdiction or constituted a grave abuse of discretion. The Court granted a cease-and-desist order on July 1, 1966, to halt enforcement of the Judge's orders while the appropriateness of the consolidation was examined.
Applicability of Article 48 of the Revised Penal Code
Central to the case was the interpretation of Article 48 of the Revised Penal Code, which addresses the conditions under which multiple offenses may be charged as a complex crime. This provision outlines two scenarios: the first involves a single act that leads to multiple grave or less grave felonies, and the second pertains to an offense being a necessary means for committing another. Therefore, the Court scrutinized whether the facts met these criteria.
Jurisprudential Precedents
The Court analyzed prior cases, emphasizing that crimes resulting from separate and distinct acts should remain separate counts. Notably, where multiple bullets are fired from various guns leading to individual deaths, the respective accused are liable for a number of distinct murder charges equivalent to the number of victims. The implication is that the act of consolidation, as attempted by the respondent Judge, conflicts with established jurisprudence.
Distinction between Complex Crimes and Separate Offenses
The distinction made in precedential cases illustrated that the nature of the acts must be consistent with the complex crime definition. In instances where various victims are slain by distinct acts or shots, they constitute separate murders rather than a singular complex crime. The respondent Judge's rationale for consolidation would disregard the nuanced nature of the attacks and diminish the charges appropriately tied to the severity of the offenses committed.
Discretion of the City Fiscal
The City Fiscal's discretion in filing appropriate informations was underscored, emphasizing that the decision must reflect a conviction that sufficient evidence exists to support the
...continue readingCase Syllabus (G.R. No. L-23771)
Case Overview
- The respondents, Tomas Narbasa, Tambac Alindo, and Rufino Borres, were indicted for multiple crimes, specifically four counts of murder and one count of frustrated murder.
- The incidents leading to the indictment occurred on the night of July 29, 1965, at the residence of Teofilo Mendoza and Valeriana Bontilao de Mendoza in Puga-an, City of Iligan.
- During the incident, multiple gunshots were fired, resulting in the deaths of Teofilo Mendoza and three minor children, as well as injuries to Valeriana.
Indictments and Judicial Proceedings
- The five criminal cases were filed based on facts gathered by the prosecuting attorney from an investigation.
- The defendants requested the consolidation of the cases into a single criminal case, arguing that all arose from the same incident and were motivated by a single impulse.
- Respondent Judge Hernando Pineda approved the consolidation on May 13, 1966, ordering the City Fiscal to unify the cases into one information.
Motion for Reconsideration
- The City Fiscal opposed the consolidation, arguing that the use of multiple firearms and the number of victims warranted separate cases.
- On May 31, 1966, the respondent Judge denied the motion for reconsideration, maintaining that the acts constituted a series of continuing acts rather than separate crimes.
Legal Questions Presented
- The primary legal question i