GR 108175; (December, 1995) (Digest)
G.R. No. 108175 . December 26, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JHONIE POLANGCO and JESSIE POLANGCO, accused-appellants.
FACTS
On December 28, 1990, in Asingan, Pangasinan, Luis Dorao was drinking beer with friends when appellants Jhonie and Jessie Polangco, along with two others at large, arrived. Jessie Polangco, armed with a lead pipe, confronted Dorao, asking, “Who boxed me?” After Dorao denied it, Jessie struck at him but missed, instead hitting Jhonie on the forehead. An incensed Jhonie declared, “we will kill him.”
The group then collectively assaulted Dorao. Jhonie and the two others stabbed him, while Jessie hit him with the pipe. They chased the fleeing victim and prevented his escape. The attack resulted in Dorao sustaining eleven stab wounds, causing his death. The appellants were convicted of Murder by the trial court and sentenced to reclusion perpetua.
ISSUE
Whether the prosecution proved beyond reasonable doubt the existence of conspiracy between the appellants in the killing of Luis Dorao.
RULING
Yes, conspiracy was sufficiently established. The Supreme Court affirmed the conviction, holding that conspiracy need not be proved by direct evidence of a prior agreement. It can be inferred from the acts of the accused before, during, and after the crime that indicate a joint purpose and concerted action.
The Court found the record replete with such indicia: the appellants arrived together at the scene; all were armed; they simultaneously ganged up on the victim; they chased him to prevent escape; none attempted to stop the assault; they threatened bystanders; and they fled together after the attack. These circumstances eloquently revealed a community of design to inflict mortal harm.
The Court also rejected the appellants’ defenses of denial and alibi, giving greater weight to the positive, spontaneous, and credible identification by prosecution eyewitnesses. The trial court’s findings on witness credibility were accorded the highest respect. The natural reluctance of witnesses to intervene, due to threats to their own lives, did not impair their credibility. Consequently, the collective actions of the appellants established conspiracy, making each equally liable for the crime of Murder. The appealed decision was affirmed in toto.