People v. Remollino

Summary

Trizon Remollino was charged with multiple murder for killing six people with a carbine on March 13, 1958. He pleaded guilty to multiple homicide before arraignment. The main issue on appeal was whether this constituted a complex crime under Article 48 of the Revised Penal Code (requiring one penalty for the most serious crime) or six separate homicides requiring separate penalties. The Supreme Court ruled that since each victim was killed by separate shots in succession, not by a single act, Article 48 does not apply. The Court distinguished this from People vs. Lawas where multiple deaths from a single impulse constituted a complex crime. The decision established that successive killings, even at short intervals, constitute separate crimes requiring individual penalties. The Court affirmed the conviction for six separate homicides, modified the sentence to ensure penalties for all six crimes, and increased indemnity to P6,000.00 per victim.