Castillo v. Donato

Summary

Teodorico Castillo was convicted of double homicide and damage to property through reckless imprudence after his Philippine National Railways bus collided with a jeepney, killing two persons and destroying the vehicle. The trial court imposed two separate indeterminate penalties totaling over nine years imprisonment, which was affirmed by the Court of Appeals. Castillo's probation application was denied due to the excessive penalty length. The Supreme Court dismissed his certiorari petition but acknowledged that only one penalty should have been imposed for what constituted a complex crime committed through a single reckless act. Since the judgment had become final, the Court referred the matter to the Chief Executive for possible executive clemency, highlighting the error in imposing multiple penalties for a single complex crime under the Revised Penal Code.