**Facts:** Santiago Paera, serving as the Punong Barangay of Mampas, Bacong, Negros Oriental, was convicted by the Municipal Circuit Trial Court of Valencia-Bacong, Negros Oriental, for three counts of Grave Threats under Article 282 of the Revised Penal Code. His conviction was subsequently affirmed by the Regional Trial Court (RTC) of Dumaguete City.
The sequence of events leading to Paera’s appeal to the Supreme Court unfolded when he restricted water distribution from a communal tank to Mampas residents, due to the tank’s location on land in a neighboring barangay owned by Vicente Darong, father of complainant Indalecio Darong. Despite warnings, Indalecio Darong continued drawing water, leading to a confrontation between him and Paera, ending with Paera threatening Indalecio Darong, his wife Diosetea, and Vicente Darong with a bolo. The prosecution and defense presented conflicting accounts of the incident, with Paera denying the charges but being found guilty by the MCTC. His appeal to the RTC, and subsequently to the Supreme Court, maintained his innocence, arguing a single count due to a “continued complex crime” notion and asserting self-defense and official duty.
**Issues:**
1. Whether Paera is guilty of three separate counts of Grave Threats.
2. Whether his liability should be limited to a single count based on the “continued complex crime” concept.
3. Whether Vicente Darong’s non-testimony affects Paera’s conviction.
4. The applicability of self-defense and official duty as justifying circumstances.
**Court’s Decision:**
The Supreme Court denied Paera’s petition, affirming the RTC’s decision for three counts of Grave Threats. It rejected Paera’s contention of a “continued complex crime,” affirming that the threats were made at different times to three individuals, thus constituting three separate crimes. The Court also addressed that the absence of Vicente’s testimony did not weaken the prosecution’s case due to sufficient evidence from other witnesses. Lastly, the Court found no justifying circumstances of self-defense or mandatory fulfillment of office duties, as Paera’s actions exceeded legal bounds.
**Doctrine:**
– The crime of Grave Threats is consummated once the threat reaches the person threatened.
– Foreknowledge of the presence of potential victims is essential to substantiate a claim for a “continued crime.”
– A complex crime under Article 48 of the RPC is constituted either by a single act resulting in two or more grave or less grave felonies or an offense as a means to commit another, neither of which applied to Paera’s case.
**Class Notes:**
– Key elements of the crime of Grave Threats include the actual threat of harm, its communication to the victim, and the distinction between separate occurrences giving rise to multiple counts of the offense.
– Foreknowledge and presence of victims at the time of the crime are crucial in the determination of a “continued crime.”
– The concept of a complex crime under Article 48 of the RPC requires a singular act with multiple legal infringements or instrumentalality towards committing another offense.
– Justifying circumstances demand the presence of unlawful aggression, reasonable necessity of the means employed, and the absence of evil motives.
**Historical Background:** The case highlights the legal intricacies surrounding the interpretation of threats and the responsibility of local officials within their official and personal capacities. It also emphasizes the importance of distinguishing between separate instances of prohibited conduct, the scope of self-defense, and the lawful execution of duties under the RPC. Through its detailed dissection, the Court reaffirms strict adherence to procedural and substantive law principles, ensuring the equitable application of justice in cases involving public servants.
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