April 2012 Philippine Supreme Court Decisions on Criminal Law and Procedure

Here are select April 2012 rulings of the Supreme Court of the Philippines on criminal law and procedure:


Composite crime; defined.  The felony of rape with homicide is a composite crime.  A composite crime, also known as a special complex crime, is composed of two or more crimes that the law treats as a single indivisible and unique offense for being the product of a single criminal impulse. It is a specific crime with a specific penalty provided by law and differs from a compound or complex crime under Article 48 of the Revised Penal Code, which states that “[w]hen a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means for committing the other, the penalty for the most serious crime shall be imposed, the same to be applied in its maximum period. People v. Villaflores,G.R. No. 184926, April 11, 2012.

Composite crime and compound crime differentiated. There are distinctions between a composite crime, on the one hand, and a complex or compound crime under Article 48 of the Revised Penal Code, on the other hand. In a composite crime, the composition of the offenses is fixed by law; in a complex or compound crime, the combination of the offenses is not specified but generalized, that is, grave and/or less grave, or one offense being the necessary means to commit the other. For a composite crime, the penalty for the specified combination of crimes is specific; for a complex or compound crime, the penalty is that corresponding to the most serious offense, to be imposed in the maximum period. A light felony that accompanies a composite crime is absorbed; a light felony that accompanies the commission of a complex or compound crime may be the subject of a separate information. People v. Villaflores, G.R. No. 184926, April 11, 2012.

Continue reading