Crimes Charged Separately Must Be Judged Separately

In Philippine law, if you are charged with multiple offenses in separate informations, you cannot be convicted of a single “complex crime.” Each charge must be considered and judged independently. This Supreme Court case clarifies this important principle, ensuring fair application of penalties and upholding the constitutional right to be informed of the charges.

[ G.R. No. 121462-63, June 09, 1999 ]

INTRODUCTION

New Year’s Eve celebrations are often filled with joy and festivity, but for the Valdez and Ferrer families, December 31, 1993, turned into a nightmare. Amidst the revelry, gunfire erupted, tragically claiming the lives of young Gerardo Valdez and Perlita Ferrer. Cipriano De Vera, Sr., Gerardo’s uncle, was accused of the killings, facing three separate informations for murder, homicide, and illegal possession of firearms. The central legal question that arose in this case wasn’t just about guilt or innocence, but about how the courts should treat multiple charges arising from a single incident when filed separately: Can these separate crimes be complexed into one?

LEGAL CONTEXT: COMPLEX CRIMES AND SEPARATE INFORMATIONS IN THE PHILIPPINES

Philippine criminal law recognizes “complex crimes” under Article 48 of the Revised Penal Code. This article addresses situations where a single act results in two or more grave or less grave felonies, or when an offense is a necessary means for committing another. Article 48 states: “Penalty for complex crimes. — When a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means for committing another, the penalty for the most serious crime shall be imposed, the same to be applied in its maximum period.”

However, a crucial distinction exists when multiple crimes, even if related, are charged in separate informations. An “information” is the formal accusation filed in court that initiates a criminal case. The Supreme Court in People vs. Legaspi (246 SCRA 206) clarified that while joint trials for separate informations are permissible for efficiency, consolidating convictions into a single complex crime is legally erroneous. The Court emphasized that doing so would violate the accused’s constitutional right to be informed of the nature and cause of the accusation against them. Each information must stand on its own, and the accused must be convicted (or acquitted) for each charge separately, based on the evidence presented for each.

CASE BREAKDOWN: PEOPLE VS. DE VERA

The case of People vs. Cipriano De Vera, Sr. unfolded in the Regional Trial Court of Lingayen, Pangasinan. The prosecution presented eyewitness testimonies from Neil and Jesusa Valdez, brother and sister of victim Gerardo, who identified Cipriano De Vera, Sr. as the shooter. Neil recounted seeing his uncle Cipriano under a mango tree, witnessing the gunshot, and seeing Gerardo fall. Jesusa corroborated Neil’s account, stating she saw Cipriano shoot Gerardo with a long firearm. Medical evidence confirmed that both Gerardo and Perlita died from gunshot wounds inflicted by similar weapons.

The defense rested on alibi. Cipriano claimed he was in a different barangay, Paurido, celebrating New Year’s Eve and then left for Manila early the next morning. His son and relatives testified to support his alibi. However, the trial court found the prosecution’s eyewitness accounts credible and rejected the alibi, citing its weakness as a defense and the lack of impossibility for Cipriano to be at the crime scene in Cayambanan.

The trial court initially convicted Cipriano of the complex crime of Murder with Homicide, along with illegal possession of firearms, sentencing him to death for the complex crime and imprisonment for the firearms charge. This decision was automatically elevated to the Supreme Court due to the death penalty imposition.

On review, the Supreme Court upheld the trial court’s factual findings regarding Cipriano’s guilt for the deaths of Gerardo and Perlita and for illegal possession of firearm. The Court stated, “Well-settled is the rule that the factual findings of, including particularly the assessment on the credibility of witnesses made by, a trial court are accorded a great degree of respect and will not, absent strong cogent reasons, be disturbed on appeal.” It found no reason to doubt the eyewitness testimonies over the alibi, noting that “…for the defense of alibi to prosper, it is not enough that the accused can prove his being at another place at the time of its commission; it is likewise essential that he can show physical impossibility for him to be at the locus delicti.”

However, the Supreme Court corrected a critical legal error: the conviction for a complex crime of Murder with Homicide. Echoing People vs. Legaspi, the Court ruled that since murder and homicide were charged in separate informations, they cannot be complexed into one crime. The Court stated, “Thus, appellant cannot be held liable for the complex crime of murder with homicide but should be held liable separately for these crimes.” Consequently, the Court modified the decision, convicting Cipriano separately for Murder (for Gerardo) and Homicide (for Perlita), and dismissing the illegal possession of firearms charge (due to prevailing jurisprudence at the time, although this aspect has since evolved).

PRACTICAL IMPLICATIONS: SEPARATE CHARGES, SEPARATE JUDGMENTS

This case reinforces a fundamental principle in Philippine criminal procedure: when the prosecution chooses to file separate informations for related offenses, the court must render separate judgments for each. It cannot merge these into a complex crime conviction, even if the offenses arise from the same incident. This ruling has significant implications:

• For Prosecutors: Carefully consider whether to file separate or single informations. While separate informations offer flexibility, they preclude complex crime convictions.
• For Defense Attorneys: Scrutinize the informations filed against their clients. If separate informations are filed for offenses that could arguably be complexed if charged together, argue against any attempt to treat them as a single complex crime during sentencing.
• For Individuals: Understand that being charged with multiple crimes in separate documents means each charge will be judged on its own merits, and you will be convicted or acquitted separately for each.

Key Lessons:

• Separate Informations Mean Separate Crimes: Philippine courts cannot convict an accused of a complex crime when the constituent offenses are charged in separate informations.
• Right to Be Informed: This ruling protects the accused’s constitutional right to be properly informed of each charge against them.
• Procedural Due Process: Adherence to proper procedure in filing charges is crucial in criminal cases.

FREQUENTLY ASKED QUESTIONS (FAQs)

Q: What is a complex crime under Philippine law?

A: A complex crime, under Article 48 of the Revised Penal Code, is either a single act constituting two or more felonies, or when one offense is a necessary means to commit another. The penalty for the most serious crime is imposed in its maximum period.

Q: What is a criminal information?

A: A criminal information is a formal written accusation filed by the prosecutor in court, charging a person with a criminal offense. It initiates the criminal proceedings.

Q: If multiple crimes arise from one incident, why file separate informations?

A: Prosecutors might file separate informations for various reasons, including strategic considerations during trial, differing evidence for each offense, or to ensure all potential charges are covered.

Q: Can I be tried jointly for crimes charged in separate informations?

A: Yes, Philippine courts can conduct joint trials for cases arising from separate informations, especially if they involve the same incident and witnesses, for judicial economy.

Q: What is the consequence if a court erroneously convicts someone of a complex crime based on separate informations?

A: As seen in People vs. De Vera, the Supreme Court will correct this error on appeal, modifying the judgment to reflect separate convictions for each offense.

Q: Does this ruling mean I can get a lighter sentence if charged separately?

A: Not necessarily lighter overall, but the sentences will be applied to each crime individually, not as a complexed single crime. The total sentence might be similar, but the legal framework is different, ensuring each charge is properly adjudicated.

Q: What should I do if I am facing multiple criminal charges?

A: Seek immediate legal counsel from a competent criminal defense lawyer to understand the charges, your rights, and the best course of action for your defense.

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