GR 150762; (January, 2006) (Digest)
G.R. No. 150762 ; January 20, 2006
Coverdale Abarquez y Evangelista, Petitioner, vs. The People of the Philippines, Respondent.
FACTS
Petitioner Coverdale Abarquez was charged as a co-conspirator in the crimes of homicide and attempted homicide. The prosecution alleged that on November 21, 1993, Abarquez, together with Alberto Almojuela, blocked the path of Jose Buenjijo Paz and Ricardo Quejong as they were going home. Almojuela attacked Paz with a knife, inflicting a wound, while Abarquez held Paz by the shoulders. Almojuela then confronted and stabbed Quejong, resulting in Quejong’s death. The prosecution’s eyewitness, Paz, testified that Abarquez restrained him during the attacks and later shouted at him as he fled to seek help.
The defense presented a different account. Abarquez, a barangay kagawad, claimed he went to the scene upon being informed of a brewing fight to pacify those involved. He testified that he tried to separate the protagonists and that he did not hold Paz or assist Almojuela in the assault. The Regional Trial Court convicted Abarquez as an accomplice to homicide, a ruling affirmed by the Court of Appeals.
ISSUE
Whether the prosecution proved beyond reasonable doubt that petitioner Coverdale Abarquez is guilty as an accomplice in the crime of homicide.
RULING
The Supreme Court acquitted Abarquez. The Court emphasized that conspiracy or accomplice liability must be proven beyond reasonable doubt as the crime itself. For one to be held liable as an accomplice, the prosecution must establish that the accused had knowledge of the criminal intent of the principal and cooperated in the execution of the offense by acts prior thereto or simultaneous therewith.
The Court found the evidence insufficient to meet this standard. The act of holding Paz, as testified to by the prosecution witness, was ambiguous. This restraint could be interpreted as facilitating the attack by Almojuela, but it was equally consistent with Abarquez’s defense that he was attempting to pacify the combatants, an act aligned with his duty as a barangay official. When the facts are susceptible to two interpretations, one consistent with innocence and the other with guilt, the evidence fails the test of moral certainty required for a conviction. The prosecution did not overcome the constitutional presumption of innocence, as Abarquez’s alleged cooperation in the crime was not established beyond reasonable doubt.