G.R. No. L-2168

FACTS:
The defendants, including Rafael Casañas, Blas Casañas, Anastasio Ligaya, and Eulalio Realon, were charged with the crime of rape against Agapita Bedico. The Court of First Instance of La Laguna found Rafael Casañas guilty as the principal author and the others as accomplices. The court considered the aggravating circumstances that the crime was committed in the house of the offended party and in the presence of her betrothed. Rafael was sentenced to reclusion temporal, while the others were sentenced to prision mayor. All were ordered to pay indemnity. The convicted defendants appealed.

ISSUE:
Whether the Court of First Instance erred in classifying Blas Casañas, Anastasio Ligaya, and Eulalio Realon merely as accomplices and not as principals in the crime of rape.

RULING:
The Supreme Court reversed the lower court’s judgment. Applying the doctrine established in United States vs. Maza, the Court held that when two or more persons unite for the execution of a criminal offense, whether they act jointly or separately but with the common purpose of consummating the same crime, each is liable as a principal. Consequently, all appellantsRafael Casañas, Blas Casañas, Anastasio Ligaya, and Eulalio Realonwere found guilty as principals of the crime of rape. Each was sentenced to seventeen years, four months, and one day of reclusion temporal, with the corresponding accessory penalties, and were held jointly and severally liable for the indemnity and support of any potential offspring.