GR 124977; (June, 2000) (Digest)
G.R. No. 124977; June 22, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISABELO RAGUNDIAZ y AUREGUE and ROLANDO FLORES y SAN MIGUEL, accused, ROLANDO FLORES y SAN MIGUEL, accused-appellant.
FACTS
The case involves the murder of Billy Cajuban on July 9, 1994, in Valenzuela, Metro Manila. Accused-appellant Rolando Flores, a taxi driver, and his co-accused Isabelo Ragundiaz were charged with acting in conspiracy. The prosecution’s case was built on circumstantial evidence. Witness Alberto Castillo testified that around 12:30 a.m., he saw Ragundiaz have an altercation with the victim, box him, poke a gun at him, and then drag him into an “El Salvador” taxi driven by Flores, accompanied by three unidentified persons.
Subsequently, witness Lito Salinas, a waiter at Skyblue Beerhouse in Kalookan City, testified that around 3:30 a.m. the same day, he saw Flores, Ragundiaz, and three others enter the establishment. He noticed Flores had a blood-stained shirt and a wound on his left hand. They arrived in the same “El Salvador” taxi. The victim’s body was discovered along a roadside in Valenzuela, with a gunshot wound to the head. The defense presented alibis, with Ragundiaz claiming he was in Makati, corroborated by his common-law wife, and Flores claiming he was at home sleeping.
ISSUE
Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of accused-appellant Rolando Flores beyond reasonable doubt.
RULING
The Supreme Court modified the trial court’s decision. It held that the evidence was insufficient to prove conspiracy between Flores and Ragundiaz. Conspiracy requires proof of a common design and concerted action, which was not established. The act of driving the taxi, by itself, does not prove Flores had knowledge of a criminal plan or participated in the killing with the same criminal intent. However, the Court found Flores guilty as an accomplice. The circumstantial evidence—his presence as the driver during the forcible taking of the victim, his presence hours later with the principal accused and a blood-stained shirt, and the lack of a credible explanation for his whereabouts—formed an unbroken chain leading to the reasonable conclusion that he knowingly and intentionally cooperated in the commission of the crime by performing indispensable acts without which the crime could not have been accomplished. His penalty was reduced accordingly, and his civil liability was adjusted to reflect his role as an accomplice.