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People v.

Villaflores committing the other, the penalty for the most


G.R. No. 184926, April 11, 2012 serious crime shall be imposed, the same to be
Bersamin, J. applied in the maximum period).
Gancayco, Group 1
There are distinctions between a composite crime and
PLAINTIFF-APPELLEE: People of the Philippines a complex or compound crime under Art. 48.
ACCUSED-APPELLANT: Edmundo Villaflores y Olano Article 266-A of RA no. 8352 or the Anti-Rape Law of
1997 defines rape, and when and how it is committed.
FACTS AND PROCEDURAL HISTORY: Art. 266-B of the same law provides for the penalties.
1. On July 3, 1999, 4-year-old Marita was found The same law sets forth the composite crimes of
raped and dead by strangulation by her father in attempted rape with homicide (punishable by
an unoccupied house near their home. The day reclusion perpetua to death) and rape with homicide
before at 10 AM, she was seen by witnesses with punishable by death). In both composite crimes, the
accused-appellant. Same witnesses used shabu homicide is committed by reason or on the occasion
with accused. One witness said he heard cries of of rape. Each of said composite crimes is punished
a child at the back of the house. Same witness with a single penalty.
said he saw accused carrying a sack towards a
vacant house. Police saw the child black and blue The phrases by reason of the rape and on the
with crushed face inside a sack. There were blood occasion of the rape are crucial in determining
stains on her lips and on her vagina. There were whether the crime is a composite crime or a complex
multiple deep lacerations at the hymen. There or compound crime.
was also a nylon cord. The witnesses pointed to  By reason of the rape - means the killing is due to
the accused as the one who abducted the child. the rape (rape is the offense that the the
The child was found to have died from asphyxia offender originally designed to commit). The
by strangulation. victim of the rape is also the victim of the killing.
2. Accused denied raping and killing the child saying The indivisibility of the homicide (attempted or
that he did not see the child on said date. He also consummated) is clear.
denied carrying a sack and throwing it at a vacant  On the occasion of the rape – harder to
lot. determine and must resort to the meaning that
3. RTC convicted accused Villafores of rape with the framers of the law intended to convey. On
homicide holding that the circumstantial the occasion of the rape refers to a killing that
evidence led to no other conclusion but that his occurs immediately before, or after, or during the
guilt was beyond reasonable doubt. Accused was commission of the attempted or consummated
sentenced to death. rape where the victim of the homicide may be a
4. CA affirmed the conviction. person other than the rape victim herself for as
long as the killing is linked to the rape. For
ISSUE: example – principal crime is rape and the
WON the RTC and CA erred in finding Accused guilty offender is fleeing the place and commits
beyond reasonable doubt of rape with homicide homicide – this will be on the occasion of rape.
through circumstantial evidence.

JUDGMENT:
NO. Conviction sustained. Accused is guilty of rape
with homicide.

RATIO:
The felony of rape with homicide is a composite
crime. A composite crime is also known as a special
complex crime and is composed of two or more
crimes that the law treats as a single and 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 RPC. (Art. 48
Provides – 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