In the case of People v. Avila (G.R. No. 195244, June 22, 2015), the Supreme Court held the difference of composite and complex crime.  A composite crime is truly distinct and different from a complex or compound crime. 

In a composite crime, the composition of the offenses is fixed by law, but in a complex or compound crime, the combination of the offenses is not specified but generalized, that is, grave and/or less grave, or one offense being the necessary means to commit the other. In a composite crime, the penalty for the specified combination of crimes is specific, but in a complex or compound crime the penalty is that corresponding to the most serious offense, to be imposed in the maximum period. A light felony that accompanies the commission of a complex or compound crime may be made the subject of a separate information, but a light felony that accompanies a composite crime is absorbed.

0 Comments