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People v. Valdez
663 SCRA 272
Two accused were tried for three counts of murder: Edwin Valdez and Eduardo Valdez. The RTC convicted them as charged. The two accused then came to the SC on final appeal, but on May 9, 2007, Edwin Valdez filed a motion to withdraw appeal , which the Court granted.
On January 18, 2012, the Court promulgated its judgment on the appeal of Eduardo Valdez, finding him guilty of three counts of homicide, instead of three counts of murder. Edwin Valdez sent to the Court Administrator a self-explanatory letter, where he pleaded for the application to him of the judgment promulgated on January 18, 2012 on the ground that the judgment would be beneficial to him as an accused. The SC granted the request of Edwin Valdez.
Whether or not the Supreme Court rightfully granted the request of Edwin Valdez and thus he is only guilty of homicide and not murder.
Yes, the grant of the request is valid and Edwin Valdez is only guilty of three counts of homicide. According to the Supreme Court, it is unavoidable for the Court to pronounce guilty of three homicides, instead of three murders, on account of the information not sufficiently alleging the attendance of treachery. The acts or omissions complained of must be alleged in such form as is sufficient to enable a person of common understanding to know what offense is intended to be charged, and enable the court to pronounce proper judgment. No information for a crime will be sufficient if it does not accurately and clearly allege the elements of the crime charged. Every element of the offense must be stated in the information.