People v. Alagao

Summary

Manila police officers were charged with complex crime of incriminatory machinations through unlawful arrest for allegedly framing a civil registrar employee by planting marked money during an unlawful arrest and investigation. The Court of First Instance granted defendants' motion to quash, finding no complex crime and lack of jurisdiction. The Supreme Court reversed, ruling that the information properly alleged a complex crime since unlawful arrest was a necessary means to plant evidence, and that the trial court had jurisdiction. This case establishes important precedent on complex crime definitions and the proper standard for evaluating motions to quash criminal informations.