GR L 67702; (January, 1991) (Digest)
G.R. No. L-67702; January 18, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. ANTONIO PERALTA y ARENAS alias “Toniong”, defendant-appellant.
FACTS
In the early morning of August 20, 1982, inside a house in San Carlos City, Margarita Talleser was feeding her ailing mother when the glass jalousies of a window shattered. Witnesses Teofista Talleser-Arenas and Marlyn Talleser saw the accused, Antonio Peralta, with half his body inside the room, aim and fire a long gun multiple times. Margarita was killed instantly by multiple gunshot wounds. The gunfire also wounded Maura Talleser and her four-year-old daughter, Jonalyn, who were in the same room. Police investigation recovered eleven empty carbine shells and a slug from the scene. Peralta was apprehended the same morning based on eyewitness statements.
At trial, Peralta interposed the defense of alibi, claiming he was fishing overnight with companions at a nearby location. The prosecution presented evidence of a possible motive, stemming from a past business dispute where Peralta resented the Talleser family for cutting ties with him. The Regional Trial Court convicted Peralta of the complex crime of murder with double less serious physical injuries, sentencing him to reclusion perpetua.
ISSUE
Whether the trial court correctly convicted the accused of a single complex crime.
RULING
No. The Supreme Court modified the trial court’s decision. The legal logic is that a complex crime under Article 48 of the Revised Penal Code exists only when a single act constitutes two or more felonies, or when one offense is a necessary means to commit another. The evidence in this case, particularly the recovery of eleven empty shells, established that Peralta fired multiple shots. The killing of Margarita and the wounding of Maura and Jonalyn were therefore not the result of a single act but of several distinct discharges of the firearm. Consequently, separate crimes were committed: one murder and two counts of less serious physical injuries. The defense of alibi was correctly rejected by the lower court as it was not physically impossible for Peralta to have been at the crime scene. The Court affirmed the murder conviction and the penalty of reclusion perpetua, but additionally imposed a penalty of four months of arresto mayor for each count of less serious physical injuries. The civil indemnity was also increased to P50,000.00.