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Subject: Basic Maxims in Criminal Law

People v. Comadre
G.R. no. 153559
June 8, 2004

Facts:
Antonio Comadre, George Comadre, and Danilo Lozano were charged with Murder with
Multiple Frustrated Murder for allegedly lobbing a hand grenade at the roof of the house of
Jaime Agbanlog. The act committed killed Robert Agbanlog and caused injury to four
companions of the deceased.

Issue:
Are Comadre et. al. guilty of the complex crime of murder with multiole attempted
murder under Article 48 of the Revised Penal Code?

Ruling:
Yes. The Court enunciated the doctrine or underlying philosophy of complex crimes in
the Revised Penal Code, which is the pro reo principle. It is intended to favour the accused by
imposing a single penalty irrespective of the crimes committed. The rationale being, that the
accused who commits two crimes with single criminal impulse demonstrates lesser perversity
than when the crimes are committed by different acts and several criminal resolutions.
Therefore, the single act by appellant detonating a hand grenade may quantitatively
constitute a cluster of several separate distinct offenses, yet these component criminal offenses
should be considered only a single crime in law which a single penalty is imposed because the
offender was impelled by a “single criminal impulse” which shows his lesser degree of
perversity. Thus, Antonio Comadre is convicted of the complex crime of Murder with Multiple
attempted Murder and sentenced to suffer a penalty of death while Gregorio Comadre and Danilo
Lozano are acquitted.