Kinds of complex crime

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In People v. Nelmida,[1] the Supreme Court distinguished the two kinds of complex crime: compound crime, when a single act constitutes two or more grave or less grave felonies, and complex crime proper, when an offense is a necessary means for committing the other. Moreover, the High Court also made a distinction that "when various victims expire from separate shots, such acts constitute separate and distinct crimes,"[2] not a complex crime.

[1] G.R. No. 184500, 11 September 2012.

[2] Id., citing People v. Gaffud, Jr., 587 Phil. 521, 534 (2008); People v. Orias, 636 Phil. 427, 447 (2010).