GR 124078; (February, 2000) (Digest)
G.R. No. 124078 February 1, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO BLANCO Y SEÑORA, accused-appellant.
FACTS
Accused-appellant Alberto Blanco, a tricycle driver, was charged with Murder along with three others for the killing of Arnel Leovido. The prosecution’s principal witness, Edgardo Tolentino, testified that on the night of August 9, 1993, he and the victim boarded Blanco’s tricycle. While en route, Blanco slowed down near three men, who boarded without any signal. Blanco then deviated from the agreed route. When Tolentino, sensing danger, demanded they stop, Blanco instead accelerated. Tolentino and Leovido jumped from the moving vehicle, after which Tolentino discovered Leovido had been stabbed. Leovido later died. Tolentino identified Blanco as the driver and recalled the tricycle’s mudguard bore the words “Bunga ng Pagsisikap.” Police traced the tricycle to its owner, who confirmed Blanco was driving it that night, leading to his identification in a police lineup.
ISSUE
Whether the accused-appellant Alberto Blanco is guilty as a co-principal in the crime of Murder.
RULING
Yes. The Supreme Court affirmed the trial court’s finding of guilt, ruling that conspiracy was sufficiently established. Conspiracy exists when the acts of the accused demonstrate a unity of purpose and concerted action toward a common criminal objective. The Court found that Blanco’s actions were not those of an innocent driver but were integral to the execution of the crime. He deliberately slowed to allow the assailants to board, deviated from the normal route without explanation, ignored the passengers’ plea to stop, and instead accelerated the vehicle, facilitating the attack and preventing escape. These coordinated acts, performed in concert with the other accused who inflicted the fatal stab wound, showed a common design to bring about the victim’s death. Consequently, even though it was a co-accused who delivered the lethal blow, Blanco’s indispensable cooperation made him equally liable as a co-principal by direct participation. The qualifying circumstance of treachery was present, as the attack was sudden and deprived the victim of any chance to defend himself. The penalty of reclusion perpetua and the awarded damages were thus upheld.