G.R. No. 127663 March 11, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO VALDEZ, accused-appellant.

FACTS

Accused-appellant Rolando Valdez was convicted by the trial court for the complex crime of Multiple Murder with Double Frustrated Murder and separately for Illegal Possession of Firearms under P.D. 1866. The charges stemmed from a shooting incident on September 17, 1995, in Manaoag, Pangasinan. Valdez and armed companions fired upon a group of six individuals riding a tricycle, resulting in the deaths of four victims and serious injuries to two others. The trial court imposed the death penalty for the complex crime and reclusion perpetua for the illegal possession charge.

ISSUE

The core issue is the correct application of the penal laws, specifically whether the enactment of Republic Act No. 8294 , which amended P.D. 1866, should be applied retroactively to benefit the accused-appellant.

RULING

The Supreme Court modified the trial court’s decision. It applied R.A. 8294 retroactively to the illegal possession charge, as it is favorable to the accused. The new law provides that if an unlicensed firearm is used in committing murder or homicide, there shall be no separate offense for illegal possession; the use of the unlicensed firearm shall merely be considered as an aggravating circumstance. Consequently, the separate conviction for illegal possession under P.D. 1866 was dismissed. However, the Court refused to apply the provision treating the use of an unlicensed firearm as a special aggravating circumstance in the murder cases retroactively, as this would be disadvantageous to the accused and akin to an ex-post facto law. The complex crime was thus deconglomerated. Valdez was found guilty of four counts of murder, each punishable by reclusion perpetua, and two counts of frustrated murder, with corresponding indeterminate penalties. The civil liabilities were affirmed.