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    People V Santos

    Uploaded by

    Erika Angela Galceran
    This document summarizes a court case from 1958 in which Jaime Santos was found guilty of rebellion against the Philippine government. Ten separate charges were filed against Santos and other defendants for the complex crime of rebellion with associated murders, robberies, and other crimes. The Supreme Court found Santos guilty of rebellion based on his confessions to participating in raids. However, the Court determined that rebellion cannot be a complex crime combined with other common crimes, as those crimes either further the goals of rebellion or are separate crimes that must be prosecuted independently. Therefore, the Court ruled Santos was only guilty of simple rebellion rather than the complex crime charged.

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    © All Rights Reserved
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    People V Santos

    Uploaded by

    Erika Angela Galceran
    131 views2 pages
    This document summarizes a court case from 1958 in which Jaime Santos was found guilty of rebellion against the Philippine government. Ten separate charges were filed against Santos and other defendants for the complex crime of rebellion with associated murders, robberies, and other crimes. The Supreme Court found Santos guilty of rebellion based on his confessions to participating in raids. However, the Court determined that rebellion cannot be a complex crime combined with other common crimes, as those crimes either further the goals of rebellion or are separate crimes that must be prosecuted independently. Therefore, the Court ruled Santos was only guilty of simple rebellion rather than the complex crime charged.

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    People v Santos

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    People v Santos

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    This document summarizes a court case from 1958 in which Jaime Santos was found guilty of rebellion against the Philippine government. Ten separate charges were filed against Santos and other defendants for the complex crime of rebellion with associated murders, robberies, and other crimes. The Supreme Court found Santos guilty of rebellion based on his confessions to participating in raids. However, the Court determined that rebellion cannot be a complex crime combined with other common crimes, as those crimes either further the goals of rebellion or are separate crimes that must be prosecuted independently. Therefore, the Court ruled Santos was only guilty of simple rebellion rather than the complex crime charged.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    131 views2 pages

    People V Santos

    Uploaded by

    Erika Angela Galceran
    This document summarizes a court case from 1958 in which Jaime Santos was found guilty of rebellion against the Philippine government. Ten separate charges were filed against Santos and other defendants for the complex crime of rebellion with associated murders, robberies, and other crimes. The Supreme Court found Santos guilty of rebellion based on his confessions to participating in raids. However, the Court determined that rebellion cannot be a complex crime combined with other common crimes, as those crimes either further the goals of rebellion or are separate crimes that must be prosecuted independently. Therefore, the Court ruled Santos was only guilty of simple rebellion rather than the complex crime charged.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Title: PEOPLE OF THE PHILIPPINES, PLAINTIIF AND APPELLEE, VS.

    JAIME
    SANTOS, ALIAS "LA PERLA", ALIAS "VELASCO", ALIAS "SANTOS" ET AL.,
    DEFENDANTS. JAIME SANTOS, APPELLANT.

    Ponente: FELIX, J.

    Date Published: September 17, 1958

    Quick Facts:

    A total of 10 separate informations were filed before the Court of First Instance of
    Pangasinan, charging the defendants therein with the complex crime of rebellion with
    murders, robberies, etc.

    Summary:

    A. Petitioner/Appellee: People of the Philippines

    B. Respondent/Appellant: Jaime Santos

    C. Resolution of the Lower Court:

     charging the defendants therein with the complex crime of rebellion with
    murders, robberies,

    This Court finds the accused Jaime Santos, alias Velasco, La Perla, guilty
    beyond reasonable doubt of the complex crime of rebellion, with multiple
    murder, arson, and robbery, etc.

    D. Issues Raised by Petitioner/Appellee: None

    E. Issues raised by Respondent/Appellant:

    (1) In not sentencing the appellant to suffer imprisonment of 1 year, 1 month and 10
    days of prision correctional;

    (2) In imposing upon the appellant the penalty of life imprisonment;


    (3) In not following the doctrine laid down in the cases of People vs. Hernandez (52
    Off. Gaz. [12] 5506; 99 Phil., 515) and People vs. Gerdnimo (53 Off. Gaz., [1] 68; 100
    Phil., 90). Appellant Santos does not controvert the findings of fact of the trial court so the
    case is limited to the single issue of whether or not there exists a complex crime of
    rebellion with murders, robberies, etc., defined and punished under the Revised Penal
    Code.

    F. Resolution of the SC:

    Santos admitted in his confession that he participated in the raids:

     On the ground of the multiplicity of offenses charged therein in violation of Section


    2-(e) of Rule 113 of the Rules of Court- cannot be considered as independent
    common crimes.

     the latter are either absorbed by the crime of rebellion if committed in pursuance
    of the aims, purposes and objectives of the rebels and in furtherance of their
    intention to overthrow the duly constituted government by force
     holding that the lower Court erred in finding appellant guilty of the complex crime
    of rebellion with murders, arson and robbery and that appellant should be only
    found guilty of simple rebellion

    G. Relevance to the topic:

    CRIMINAL LAW; REBELLION; CRIME CANNOT BE COMPLEXED WITH OTHER


    COMMON CRIMES. — There is no question that appellant committed the crime of
    rebellion, but as this Court already held in the cases of People v. Amado V. Hernandez
    Et. Al., 99 Phil., 515 and the later case of People v. Geronimo, 100 Phil., 90 (by a voting
    of 7 against 4) this crime cannot be complexed with other common crimes, because the
    latter are either absorbed by the crime of rebellion if committed in pursuance of the aims,
    purposes and objectives of the rebels and in furtherance of their intention to overthrow
    the duly constituted government by force, or are independent common crimes which had
    no connection with the rebellion and must be separately prosecuted in the proper court
    within the territorial jurisdiction of which the same had been committed.

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