GR 115998; (June, 2000) (Digest)
G.R. No. 115998; June 16, 2000
RICARDO SALVATIERRA, RODRIGO ASUNCION and MANUEL RAMIREZ, petitioners, vs. COURT OF APPEALS and the PEOPLE OF THE PHILIPPINES, respondents.
FACTS
An Information for homicide was filed against Luis Alina, Rodrigo Asuncion, Manuel Ramirez, Jun D. Ignacio, and Ricardo Salvatierra, alleging they conspired to stab Rolando Samonte, causing his death. The fact of death from stab wounds was undisputed. During trial, two prosecution eyewitnesses identified only Luis Alina as the one who actually stabbed the victim. They testified that petitioners Salvatierra and Ignacio were inside a jeep and did nothing, while petitioners Asuncion and Ramirez had already fled to their nearby homes prior to the stabbing. Only Alina presented evidence for the defense, claiming self-defense.
The trial court convicted all accused of homicide, finding conspiracy. The Court of Appeals affirmed the conviction but modified the penalty. Petitioners Salvatierra, Asuncion, and Ramirez filed this petition, arguing conspiracy was not proven. They highlighted that their unresolved demurrers to evidence contended the prosecution failed to establish any unity of criminal purpose between them and Alina.
ISSUE
Was there sufficient evidence to establish conspiracy among all the accused in the killing of Rolando Samonte?
RULING
No. The Supreme Court acquitted petitioners Salvatierra, Asuncion, and Ramirez, along with non-appealing accused Ignacio and Ramirez, due to lack of proof of conspiracy. The legal logic is grounded in the principle that conspiracy must be proven as clearly and convincingly as the crime itself. It cannot be presumed but must be established by evidence of concerted action towards a common criminal objective.
The prosecution evidence only showed that Luis Alina alone perpetrated the stabbing. The witnesses’ accounts positively stated that the petitioners were either passive spectators inside a vehicle or had already departed from the scene. Their mere presence at the location, without any act demonstrating a prior agreement or cooperation in the criminal design, is insufficient to infer conspiracy. The trial court’s inference of guilt from their failure to attend a hearing, treated as jumping bail, was erroneous, as flight alone does not prove conspiracy. Since conspiracy was not established, individual criminal liability did not attach to the petitioners for Alina’s independent act. The Court affirmed only Alina’s conviction, as he did not appeal the appellate court’s decision.