G.R. No. 17763. July 28, 1923.
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. PROCESO BUSTOS, ET AL., defendants-appellants.

FACTS

The appellants, Proceso Bustos (Municipal President), Felipe Bustos (Municipal Secretary), Jose Blanco, Filomeno Sunga (Chief of Police), Donato Benosa, and Irineo Cailao (policeman), were convicted of homicide for the killing of Liborio Bustos (Vice President). The killing occurred on June 19, 1920, inside a circus tent in Macabebe, Pampanga. Proceso Bustos harbored a belief that Liborio had an affair with his wife, and political animosity existed between Jose Blanco and Liborio. During the circus, Liborio sat among the appellants and their associates. He was suddenly seized by Ronquillo and Cailao, held by Sunga from behind, and assaulted by the group. Felipe Bustos and Jose Blanco were prominent in the assault, with Blanco using a revolver. Proceso Bustos then approached with a dagger and stabbed Liborio, causing his death. The trial court found all six appellants guilty as principals, with the aggravating circumstance of superior strength, and sentenced them to reclusion temporal.

ISSUE

Whether the appellants, other than Proceso Bustos who inflicted the fatal stab, are liable as co-principals in the crime of homicide.

RULING

Yes. The conviction of all appellants is affirmed. The court found that the appellants acted in concert with a common purpose to inflict harm upon Liborio Bustos. The assault was not a spontaneous or isolated act by Proceso Bustos alone. The simultaneous seizure of Liborio by Ronquillo and Cailao, the holding by Sunga, and the beating by the others created a situation where Liborio was rendered helpless and at the mercy of the group. This collective action facilitated and was integral to Proceso Bustos’s act of stabbing the victim. The appellants’ acts showed a community of criminal design, making them co-principals by direct participation and cooperation. The claim that they were merely performing official duty to prevent Liborio from drawing a weapon is belied by the evidence of a pre-existing grudge and the nature of the concerted attack. The aggravating circumstance of superior strength was correctly appreciated due to the number of assailants against a single, restrained victim. The penalty imposed is in accordance with law.