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    People Vs Gaffud

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    Ian Marco
    The Supreme Court of the Philippines ruled that Bernardino Gaffud, Jr. was guilty of the complex crime of double murder for killing Manuel Salvador and Analyn Salvador by burning down their house. Direct evidence from witnesses placed Gaffud at the scene of the crime and established his participation in the killings. The Court held that conspiracy was not essential to convict Gaffud since there was direct evidence of his participation. It also held that Gaffud's actions constituted a complex crime of double murder, not two separate counts, and was therefore only subject to one penalty under the law.

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    People Vs Gaffud

    Uploaded by

    Ian Marco
    91 views2 pages
    The Supreme Court of the Philippines ruled that Bernardino Gaffud, Jr. was guilty of the complex crime of double murder for killing Manuel Salvador and Analyn Salvador by burning down their house. Direct evidence from witnesses placed Gaffud at the scene of the crime and established his participation in the killings. The Court held that conspiracy was not essential to convict Gaffud since there was direct evidence of his participation. It also held that Gaffud's actions constituted a complex crime of double murder, not two separate counts, and was therefore only subject to one penalty under the law.

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    566 SCRA 76

    Original Title

    People vs Gaffud

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    The Supreme Court of the Philippines ruled that Bernardino Gaffud, Jr. was guilty of the complex crime of double murder for killing Manuel Salvador and Analyn Salvador by burning down their house. Direct evidence from witnesses placed Gaffud at the scene of the crime and established his participation in the killings. The Court held that conspiracy was not essential to convict Gaffud since there was direct evidence of his participation. It also held that Gaffud's actions constituted a complex crime of double murder, not two separate counts, and was therefore only subject to one penalty under the law.

    Copyright:

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

    People Vs Gaffud

    Uploaded by

    Ian Marco
    The Supreme Court of the Philippines ruled that Bernardino Gaffud, Jr. was guilty of the complex crime of double murder for killing Manuel Salvador and Analyn Salvador by burning down their house. Direct evidence from witnesses placed Gaffud at the scene of the crime and established his participation in the killings. The Court held that conspiracy was not essential to convict Gaffud since there was direct evidence of his participation. It also held that Gaffud's actions constituted a complex crime of double murder, not two separate counts, and was therefore only subject to one penalty under the law.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    People vs.

    Gaffud
    G.R. No. 168050. September 19, 2008
    Plaintiff-appellee: People of the Philippines
    Accused-appellant: Bernardino Gaffud
    Ponente: C.J. Puno
    FACTS:
    Accused-appellant Bernardino Gaffud, Jr. was found guilty of two (2) counts of
    murder for killing Manuel Salvador and Analyn Salvador by means of
    fire. Evidence for the prosecution presented the following:
    1) That on the night of May 10, 1994, Orly Salvador, while on his way to the
    house of his uncle Manuel Salvador, heard two gunshots and thereafter saw the
    house of his uncle burning. He saw three persons within the vicinity of the
    burning house, one of whom he identified as appellant Gaffud, Jr.
    2) That Dan Dangpal, neighbor of the deceased, at about 8:00 PM that evening,
    heard successive gunshots and saw the deceased’s house burning.
    3) That prior the incident, Barangay Captain Potado Ballang saw the appellant a
    few meters away from the house of the deceased.
    4) That earlier that day, Dominga Salvador, common-law wife of Manuel
    Salvador and mother of Analyn Salvador, went to the house of the appellant to
    inquire about her husband’s share in the construction of the barangay hall.
    Dominga also related that had earlier filed a complaint against the appellant and
    his brother for slaughtering her pig.
    In his appeal, the appellant argued that the court failed to rule and resolve
    whether or not conspiracy existed, despite the fact that there was no proof as to
    what overt acts he committed which would constitute the crime of murder.
    ISSUE:
    1) Whether or not there was conspiracy.
    2) Whether or not accused-appellant should be held liable for two (2) separate
    counts of murder or for the complex crime of double murder.
    HELD:
    1) Conspiracy, in this case, is not essential. The rule is that in the absence of
    evidence showing the direct participation of the accused in the commission of
    the crime, conspiracy must be established by clear and convincing evidence in
    order to convict the accused. In the case at bar, however, direct participation of
    accused-appellant in the killing of the victims was established beyond doubt by
    the evidence of the prosecution. Thus, a finding of conspiracy is no longer
    essential for the conviction of accused-appellant.
    2) No. The Court ruled that in a complex crime, although two or more crimes
    are actually committed, they constitute only one crime in the eyes of the law as
    well as in the conscience of the offender. The burning the house of Manuel
    Salvador, with the main objective of killing the latter and his daughter, resulting
    in their deaths resulted in the complex crime of double murder. Hence, there is
    only one penalty imposed for the commission of a complex crime.

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