Santiago vs Garchitorena

G.R. No. 109266 December 2, 1993

Facts:Senator Miriam Defensor Santiago during her time as

Commissioner of the Commission on Immigration and Deportation
accepted 32 aliens under the “Alien Legalization Program” who were
found not to have enough qualifications to become citizens of the
Philippines.
Issue:Whether or not Senator Santiago should be charged thirty
two times or only once for all instances mentioned?
Held:The Supreme Court decided that the Senator should only be
charged with one information. She is being charged under Anti-
Graft and Corrupt Practices Act which is a special law and the
doctrine of delitocontinuado can be applied. Therefore, only one
information can be charged to the senator because it was a
continuous crime.

People vs Jaranilla
G. R. No. L-28547 February 22, 1974

Facts:The accused went on their way to steal six (6) fighting cocks
from the chicken coop of Valentin Baylon. As they were trying to
escape two policemen who were trying to apprehend them, Jaranilla
fired his gun hitting a policeman who eventually died at the
hospital.
Issue: Whether or not everyone who stole the fighting cocks should
be charged withhomicide for the death of the policeman?
Held:The Supreme Court decided that the group conspired to steal
the fighting cocks from the chicken coop of Valentin Baylon but not
for the killing the policeman.It is only Jaranilla who should be liable
for the crime of homicide but the other individuals should only be
liable for stealing the six (6) fighting cocks.

PEOPLE VS. MANOLITO LUCENA

GR No. 190632, February 26, 2014

Facts:
On April 28, 2003, at around 11:30 p.m., while AAA, who was then 17
years old, was walking and chatting with her friends along one of the
streets of San Dionisio, Paranaque City,two barangay tanods, approached
and informed them that they were being arrested for violating a city
ordinance imposing curfew against minors. AAAs’s companions managed
to escape and she was then ordered by the barangay tanods to board the
tricycle, brought by the two barangay tanods to San Dionisio Barangay
Hall. The appellant told the other tanod that he will just be the one to
bring AAA back to her house. But the appellant threatened that he would
kill her once she resisted. He then took out the backseat of the tricycle
and positioned it in a grassy area and subsequently pointed a gun at her
and commanded her to lie down and to take off her clothes. The appellant
later put the gun down on the ground and inserted his penis into AAA’s
vagina despite the latter’s plea not to rape her. Satisfied, the appellant
stopped. But, after a short while, or after about five minutes, the
appellant, once again, inserted his penis into AAA’s vagina. Thereafter, he
stopped. On the third time, he inserted his penis into her vagina. Fulfilling
his bestial desire, he stopped and ordered AAA to dress up. The appellant
threatened AAA that he would kill her should she tell anyone about what
happened between them. He then brought AAA in front of a school in
Paranaque City. Medical exam by Dr. Tan shows evidence of lacerations in
the hymen, vagina, and perianal skin indicative of abuse. This was done
the day after the incident when the victim mustered enough courage to
report what happened. The appellant denied the allegations at first then
afterwards appellant attested that the victim did not resist physically. 
As to the number of rapes committed. The appellant, citing People v.
Aaron (Aaron Case),  insists that he cannot be convicted of three (3)
counts of rape despite the three (3) penetrations because he was
motivated by a single criminal intent. This Court finds this contention
fallacious.(Continuing Crime)|(|(
Issue:
Whether or not Lucena is guilty of three counts of rape.
Held:
YES. We agree with the trial court that herein appellant should be
convicted of three (3) counts of rape. It appears from the facts that the
appellant thrice succeeded in inserting his penis into the private part of
AAA. The three (3) penetrations occurred one after the other at an
interval of five (5) minutes wherein the appellant would rest after
satiating his lust upon his victim and, after he has regained his strength,
he would again rape AAA. Hence, it can be clearly inferred from the
foregoing that when the appellant decided to commit those separate and
distinct acts of sexual assault upon AAA, he was not motivated by a single
impulse, but rather by several criminal intent. Hence, his conviction for
three (3) counts of rape is indubitable.
Also, the circumstances in the present case, however, are far
different from the Aaron Case In Aaron Case, the three penetrations
occurred during one continuing act of rape in which the accused was
obviously motivated by a single criminal intent| .

This Court sustains the findings of both lower courts that, indeed,
the three insertions into AAA were in satiation of successive but distinct
criminal carnality. Therefore, the appellant’s conviction for three counts of
rape is proper.

Santiago Paera Vs. People of the Philippines (G.R. No. 181626 May 30, 2011)

FACTS:
As punong barangay, Santiago allocated his constituent’s use of communal
water coming from a communal tank by limiting distribution to the residents of
his contituents. Despite Santiago’s scheme, Indalecio continued drawing
water from the tank. Santiago reminded Indalecio of the water distribution
scheme and cut Indalecios access.

The following day, Santiago inspected the tank after constituents complained
of water supply interruption. Santiago discovered a tap from the main line
which he promptly disconnected. To stem the flow of water from the ensuing
leak, Santiago, using a borrowed bolo, fashioned a wooden plug. It was at this
point when Indalecio arrived. Santiago then, without any warning, picked-up
his bolo and charged towards Indalecio, shouting Patyon tikaw! (I will kill
you!). Indalecio ran for safety, passing along the way, Diosetea. Upon seeing
Santiago, Diosetea inquired what the matter was. Instead of replying,
Santiago shouted “Wala koy gipili, bisag babaye ka, patyon tikaw!” (I dont
spare anyone, even if you are a woman, I will kill you!). Diosetea similarly
scampered and sought refuge in the nearby house of a relative. Unable to
pursue Diosetea, Santiago turned his attention back to Indalecio. As Santiago
chased Indalecio, he passed Vicente, and, recognizing the latter, repeatedly
thrust his bolo towards him, shouting “Bisag gulang ka, buk-on nako imo ulo!”
(Even if you are old, I will crack open your skull!).

Santiago was charged for three (3) counts of Grave Threats.

Santiago claimed that he can only be charged for a single count of the
continued complex crime of Grave Threats. He argued that there is a single
crime committed through a series of acts arising from one criminal intent.

ISSUE: Whether or not Santiago is guilty of three counts of Grave Threats

RULING: Yes. Santiago is liable for 3 counts of Grave Threats under Article
282. Any person who shall threaten another with the infliction upon the person
of the latter or his family of any wrong amounting to a crime will be liable for
Art 282. The felony was consummated as soon as the threats come to the
knowledge of the person threatened. It is clear that Santiago’s threat to kill
Indalecio and Diosetea and crack open Vicente’s skull are wrongs on the
person amounting to at least homicide and serious physical injuries
punishable under the RPC. The threat was consummated having spoken the
threats at different points in time to the 3 individuals, albeit in rapid
succession, making Santiago incur 3 separate criminal liabilities because not
having known in advance of the Darongs’ presence near the water tank at the
time in question, Santiago could not have formed any intent to threaten any of
them until he came across each of them.