G.R. No. 252859 , March 15, 2023
People of the Philippines, Plaintiff-Appellee, vs. Ronnie Ralla y Bulaquiña, Accused-Appellant.

FACTS

The accused-appellant, Ronnie Ralla y Bulaquiña, was charged under four separate Informations for crimes committed on the same occasion: frustrated murder against Ma. Katrina R. Herrera (Crim. Case No. 1073-V-17); frustrated murder against Jesusa Reyes Herrera (Crim. Case No. 1074-V-17); robbery with homicide against Simeon Fausto Herrera (Crim. Case No. 1075-V-17); and attempted murder against Josefina Dela Cruz Reyes (Crim. Case No. 1076-V-17). The trial court convicted him of attempted homicide, frustrated homicide, robbery with homicide, and attempted murder, respectively. The appellate court modified the penalties. The majority decision of the Supreme Court resolved to convict the appellant of the single complex crime of robbery with homicide, absorbing all other felonies committed on the occasion of the robbery, relying on People v. De Jesus.

ISSUE

Whether the accused-appellant can be convicted of the single complex crime of robbery with homicide, despite being charged under four separate Informations for distinct crimes, without violating his constitutional right to be informed of the nature and cause of the accusation against him.

RULING

The dissenting opinion argues that the accused-appellant should be convicted separately as charged in the four Informations, not of a single complex crime of robbery with homicide. The constitutional right of the accused to be informed of the nature and cause of the accusation (Section 14[2], Article III, 1987 Constitution ) prohibits conviction of an offense not clearly charged. The hornbook doctrine is that an accused cannot be convicted of a crime unless it is alleged or necessarily included in the Information. When components of a complex crime are alleged in separate Informations, the accused must be convicted of separate crimes to avoid violating this right, even if the penalty for the complex crime would be more favorable. The dissent cites People v. Manalili and People v. Legaspi, where the Court refused to convict for a complex crime when separate Informations were filed, holding the accused liable for the separate crimes charged. The dissent distinguishes People v. De Jesus, as it involved a single Information for the complex crime. Here, the appellant failed to question the separate Informations via a motion to quash under Rule 117 of the Rules of Court, thereby waiving any defects and accepting the charges as filed. Therefore, the dissenting vote is to affirm the appellant’s separate convictions for attempted homicide, frustrated homicide, robbery with homicide, and attempted murder as charged in the four Informations.