In Malana v. People, the Supreme Court affirmed the conviction of Dominador Malana and Rodel Tiaga for the complex crime of murder with frustrated and attempted murder, clarifying the application of Article 48 of the Revised Penal Code. The ruling underscores that when a single act results in multiple felonies, the most severe penalty will be applied, offering clarity on how Philippine law addresses situations where one action leads to multiple grave consequences. This provides guidance on how the judiciary assesses accountability and prescribes punishment in cases involving complex crimes arising from a single act.

A Deadly Act: How Does a Single Explosion Result in Multiple Crimes?

The case stems from a harrowing incident on May 28, 2000, in San Jose del Monte, Bulacan, where Dominador Malana and Rodel Tiaga, along with Elenito Malana (who was later acquitted), were accused of murder and multiple frustrated murder. The event led to the death of Betty Capsa-Roxas and injuries to her daughter, Suzette Roxas, and granddaughter, Jenny Rose de la Cruz. The prosecution presented Vicente Roxas Jr., Betty’s husband, and Suzette Roxas as key witnesses, with their testimonies forming the basis for the conviction of Dominador and Rodel.

The testimonies revealed a disturbing sequence of events: an attack on the Roxas family home initiated with arson and culminating in an explosion. Vicente recounted being awakened by the sound of dogs barking, only to find the kitchen door engulfed in flames. As Betty opened the main door to seek help, the accused appeared. Fearing for his life due to prior threats, Vicente fled to seek help. Meanwhile, Suzette witnessed the accused throwing an explosive device into her bedroom, which resulted in Betty’s death and severe injuries to Suzette, including the amputation of her leg. The defense presented alibis, but the trial court gave credence to the eyewitness accounts of Vicente and Suzette, leading to the conviction of Dominador and Rodel.

The Regional Trial Court (RTC) found Dominador and Rodel guilty of separate crimes of murder and frustrated murder, but acquitted Elenito due to reasonable doubt. However, on appeal, the Court of Appeals affirmed the guilt of Dominador and Rodel, but modified the ruling, determining that they were liable for the complex crime of murder with frustrated murder and attempted murder. This reclassification led to a modification in their sentence to the penalty prescribed for the most serious crime—death, later commuted to reclusion perpetua due to Republic Act No. 9346.

At the heart of the Supreme Court’s analysis was Article 48 of the Revised Penal Code, which addresses complex crimes. The article states: “When a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means of committing the other, the penalty for the most serious crime shall be imposed, the same to be applied in its maximum period.” In this case, the single act of throwing an explosive device resulted in three distinct felonies: the murder of Betty, the frustrated murder of Suzette, and the attempted murder of Jenny.

The Supreme Court emphasized the credibility of the prosecution’s witnesses, particularly Suzette, stating:

We have no doubt in Suzette’s testimony as she would not have lightly accused the herein accused-appellants if they were not the true malefactors of the crime committed. Indeed, as a direct victim, who lost her left leg to the crime; as mother, who had to bear the sight of her eight-month old baby injured by burns; and as a daughter, who witnessed her own mother burn to death, Suzette could never have just pinpointed to anyone to the crime.

The court also dismissed the appellants’ defense of alibi, stating that it was outweighed by the positive identification made by the prosecution witnesses. The court found that the intent to kill was evident in the appellants’ actions of throwing the explosive device, and that the use of an explosive device qualified the crime as murder under Article 248(3) of the Revised Penal Code. The Court also reiterated its earlier holding in People v. Comadre on the use of explosives as a qualifying circumstance.

When the killing is perpetrated with treachery and by means of explosives, the latter shall be considered as a qualifying circumstance.

With respect to damages, the Supreme Court upheld the award granted by the Court of Appeals, including compensation for the loss of the victims’ house and possessions, medical and burial expenses, civil indemnity, and moral damages.

FAQs

What was the key issue in this case?	The key issue was whether the accused were guilty of murder, frustrated murder, and attempted murder due to a single act—throwing an explosive device into a house. The court had to determine if Article 48 of the Revised Penal Code, concerning complex crimes, applied.
What is a complex crime under Philippine law?	A complex crime occurs when a single act results in two or more grave or less grave felonies, or when one offense is a necessary means of committing another. In such cases, the penalty for the most serious crime is imposed in its maximum period.
How did the Court determine the intent to kill?	The Court inferred the intent to kill from the appellants’ act of throwing an explosive device into the direction of the victims. This action demonstrated a clear intention to cause serious harm or death, thus satisfying the element of intent.
What was the significance of the explosive device in this case?	The use of an explosive device was a critical factor that qualified the crime as murder under Article 248(3) of the Revised Penal Code. This provision specifically addresses killings committed by means of explosion, highlighting the severity of the act.
What is the equipoise rule, and why didn’t it apply here?	The equipoise rule states that when evidence is evenly balanced, the presumption of innocence should favor the accused. This rule didn’t apply because the prosecution’s evidence was overwhelming, with positive identification of the appellants as the perpetrators.
What damages were awarded to the victims?	The victims were awarded damages including compensation for the loss of their house and possessions (P300,000.00), medical and burial expenses (P15,340.15 and P9,610.00, respectively), civil indemnity (P50,000.00), and moral damages (P50,000.00).
What is the effect of Republic Act No. 9346 on the penalty in this case?	Republic Act No. 9346 prohibits the imposition of the death penalty. As a result, the death penalty initially imposed by the Court of Appeals was reduced to reclusion perpetua, which is life imprisonment without the possibility of parole.
Why was Elenito Malana acquitted in this case?	Elenito Malana was acquitted due to reasonable doubt. Suzette Roxas did not positively identify him as the third man involved in the crime, and his physical appearance did not match the description provided, leading to his acquittal.

In conclusion, the Supreme Court’s decision in Malana v. People affirms the application of Article 48 in complex crimes, particularly those arising from a single act that results in multiple felonies. The ruling underscores the gravity of using explosive devices, emphasizing the intent to kill, and affirming the credibility of eyewitness testimony. It also shows a practical consequence of RA 9346 which abolished the death penalty.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Malana vs. People, G.R. No. 173612, March 26, 2008