Multiplicity of charges for light felonies; waiver
The slight physical injuries caused by GLENN to the ten other victims through
reckless imprudence would, had they been intentional, have constituted light
felonies. Being light felonies, which are not covered by Article 48, they should
be treated and punished as separate offenses. Separate informations should have,
therefore, been filed. It must be noted that only one information (for multiple
murder, multiple frustrated murder and multiple attempted murder) was filed with
the trial court. However, nothing appears in the record that GLENN objected to
the multiplicity of the information in a motion to quash before his arraignment.
Hence, he is deemed to have waived such defect. Under Section 3, Rule 120 of the
Rules of Court, when two or more offenses are charged in a single complaint or
information and the accused fails to object to it before trial, the court may
convict the accused of as many offenses as are charged and proved, and impose on
him the penalty for each of them. (People vs. delos Santos, G.R. No. 131588, 27
March 2001, 355 SCRA 415)
Note the 2010 case of Ivler v. Modesto San Pedro: https://www.projectjurisprudence.com/2017/06/complexing-quasi-crimes-article-365.html.