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People V. Punzalan

Arturo Punzalan was found guilty of the compound crime of double murder with multiple attempted murder. On August 10, 2002, Punzalan got into a fight at a bar with some members of the Philippine Navy. Later that night, he drove his car into the navy group as they were walking back to camp, killing two and injuring the others. The court ruled that Punzalan committed a single act with the intent to kill all the navy personnel, constituting the complex crime of double murder and multiple attempted murder under Article 48 of the Revised Penal Code. Punzalan was properly convicted of this compound crime.

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Sarah Jane Usop
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816 views1 page

People V. Punzalan

Arturo Punzalan was found guilty of the compound crime of double murder with multiple attempted murder. On August 10, 2002, Punzalan got into a fight at a bar with some members of the Philippine Navy. Later that night, he drove his car into the navy group as they were walking back to camp, killing two and injuring the others. The court ruled that Punzalan committed a single act with the intent to kill all the navy personnel, constituting the complex crime of double murder and multiple attempted murder under Article 48 of the Revised Penal Code. Punzalan was properly convicted of this compound crime.

Uploaded by

Sarah Jane Usop
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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SARAH JANE U.

USOP
PEOPLE v. ARTURO PUNZALAN, GR No. 199892, 2012-12-10
Art 48 Compound Crime

Facts:
crime of double murder with multiple attempted murder,...
Seaman 1st Class (SN1) Arnulfo Andal, SN1 Antonio Duclayna, SN1 Evelio Bacosa,
SN1 Cesar Domingo, SN1 Danilo Cuya, and SN1 Erlinger Bundang were among the
members of the Philippine Navy sent for schooling at the Naval Education and Training
Command (NETC) at San Miguel, San Antonio, Zambales.
On August 10, 2002, at 5 or 6 p.m., they all went to the All-in-One Canteen to drink and
at 10 p.m. transferred to Aquarius, a videoke bar where SN1Bacosa and appellant
Punzalan got into a fight.
The Navy group walked back to the NETC Camp to avoid aggravating the conflict. The
appellant, however, drunk drove a maroon Nissan with plate number DRW 706 and
followed the group to the camp. The navy sentries flagged down Punzalan and heard
him threaten to kill the Navy members he fought in the bar.
Punzalan charged forward despite being flagged down, hit the group of navy personnel
from behind, and sped away resulting to the death of Andal and Duclayna, and injuries
to the rest of the group.
Issues:
Is appellant guilty of the compound crime of double murder with multiple attempted
murder?
Ruling:
The felony committed by appellant as correctly found by the RTC and the Court of
Appeals, double murder with multiple attempted murder, is a complex crime
contemplated under Article 48 of the Revised Penal Code:
Appellant was animated by a single purpose, to kill the navy personnel, and committed
a single act of stepping on the accelerator, swerving to the right side of the road
ramming through the navy personnel, causing the death of SN1 Andal and SN1
Duclayna and, at the same time, constituting an attempt to kill SN1 Cuya, SN1 Bacosa,
SN1 Bundang and SN1 Domingo.
The crimes of murder and attempted murder are both grave felonies. The law attaches
an afflictive penalty to capital punishment (reclusion perpetua to death) for murder while
attempted murder is punished by prision mayor, an afflictive penalty.

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