People v. Remollino
REITERATIONFacts
The Antecedents: The accused, Trizon Remollino alias Eming, was charged with multiple murder for allegedly shooting six individuals, Isabelo Nozuelo, Carlos Nozuelo, Francisco Sepnio, Jacinto Sepnio, Santos Moreno, and Epifanio Bascos, with treachery and evident premeditation, inflicting mortal wounds that caused their deaths. Procedural History: Before arraignment, the accused offered to plead guilty to the lesser offense of multiple homicide, which the trial court allowed. The court rendered judgment finding the accused guilty of sextuple homicides, imposing a penalty of not less than eight (8) years of prision mayor to not more than fourteen (14) years and eight (8) months of reclusion temporal for each of three homicidal acts, capped by Article 70 of the Revised Penal Code, and ordering indemnity to the heirs of each deceased. The Petition: The accused appealed directly to the Supreme Court, arguing that the trial court erred in imposing separate penalties for the homicides and in refusing to apply Article 48 (complex crimes) and paragraph 5 of Article 64 of the Revised Penal Code. He contended that the offenses should have been treated as a complex crime.
Issue(s)
Whether Article 48 of the Revised Penal Code, concerning complex crimes, is applicable when an accused kills six persons successively and at short intervals with six separate acts. Whether the trial court erred in imposing separate penalties for the homicidal acts instead of a single penalty for a complex crime. Whether the trial court correctly appreciated the mitigating circumstances of a plea of guilty and obfuscation in imposing the penalty.
Ruling
The Supreme Court affirmed the judgment of the trial court with modifications. It held that the accused is guilty beyond reasonable doubt of six separate homicides. The penalty imposed was affirmed, and the indemnity to the heirs of each of the six deceased was increased to P6,000.00 each.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that Article 48 of the Revised Penal Code (RPC), pertaining to complex crimes, is not applicable in this case. The Court found, based on the allegations of the information admitted by the appellant's plea of guilty, that he shot six persons successively and at short intervals, and that the deaths were the result of six separate acts, not a single act. It was emphasized that it cannot be plausibly contended that only one shot or single act killed all six victims. Jurisprudence consistently holds that such acts constitute separate crimes, rather than a complex crime, requiring distinct acts against different persons for each offense. The Court cited numerous precedents, such as U.S. vs. Ferrer, People vs. Alfinado, People vs. Jose Pardo, et al., People vs. Layos, and People vs. Meliton Buyco, all affirming that successive shots or distinct acts, even in close proximity, create separate criminal liabilities. On Issue 2: The Court affirmed that separate penalties should be imposed for each homicidal act. It explicitly stated that since the appellant alone killed all six victims, one after the other, with one shot each, these constituted six distinct crimes. The trial court's initial imposition of penalties for only three homicidal acts, citing Article 70, was upheld in principle, but the Supreme Court clarified that the appellant should be sentenced to suffer the same penalty in each of the other three (3) crimes he had committed, beyond what the trial court had expressly stated. This approach aligns with the doctrine that when distinct acts lead to multiple deaths, each act is punished separately, with the total penalty capped at forty years under Article 70, paragraph 4 of the RPC. On Issue 3: The Supreme Court inferred that the trial court had indeed appreciated the mitigating circumstance of a plea of guilty. This conclusion was drawn because the maximum penalty of 14 years and 8 months of reclusion temporal imposed for each homicide fell within the minimum of the penalty range fixed for the crime, given the absence of any aggravating circumstance. The Court reasoned that for the penalty to be within the minimum, the appreciation of a mitigating circumstance like a plea of guilty would be logical. However, regarding the alleged mitigating circumstance of obfuscation, the Court found no evidence presented by the appellant to prove its existence, thus refusing to consider it.
Main Doctrine
When multiple deaths result from distinct and separate acts, even if committed successively and at short intervals, they constitute separate crimes and not a complex crime under Article 48 of the Revised Penal Code, unless the acts were performed in a single impulse or as a necessary means to commit the other.