GR 205298; (September, 2014) (Digest)
G.R. No. 205298 , September 10, 2014
LEOPOLDO QUINTOS y DELAMOR, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Leopoldo Quintos, along with his brothers Pedro, Rolly, and Lando Quintos, and Narciso Buni, was charged with Frustrated Homicide and Homicide. The charges stemmed from an incident on January 15, 2008, in Brgy. Laois, Labrador, Pangasinan. The prosecution’s version, as established through witnesses including victims Robert dela Cruz and Felomina dela Cruz, and eyewitness Eduardo Oyando, was that the victims were walking along a barangay road when they were accosted by the armed accused. The accused gave chase as the victims fled. Pedro struck Robert with a samurai, and Rolly hit him with a stone. Lando struck Freddie dela Cruz at the back of the head, and petitioner joined Lando in hacking Freddie, who sustained injuries causing the loss of fingers. Rolly then crushed Freddie’s chest with a stone. Pedro also attacked Felomina dela Cruz, slashing her nape. Narciso Buni prevented Eduardo Oyando from helping by aiming a bolo at him. Freddie dela Cruz later died from his injuries. The defense presented a different version, claiming the victims initiated the confrontation and that Pedro acted in defense of his brother during a struggle over a bolo. The Regional Trial Court convicted petitioner and his co-accused of Homicide for Freddie’s death and Attempted Homicide for the injuries to Robert and Felomina. The Court of Appeals affirmed the conviction in toto.
ISSUE
1. Whether the prosecution proved petitioner’s guilt beyond reasonable doubt.
2. Whether conspiracy existed among the accused.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals.
1. On the question of proof of guilt, the Court held that a petition for review under Rule 45 is limited to questions of law. The factual findings of the trial court, affirmed by the Court of Appeals, are generally conclusive and binding. The Court found no reason to deviate from this rule, as the trial court’s assessment of witness credibility, including its finding that the prosecution witnesses were more credible than the defense, is accorded great respect. The defense of denial could not prevail over the positive identification by the prosecution witnesses.
2. On the issue of conspiracy, the Court ruled that conspiracy was sufficiently established. Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. It may be deduced from the mode and manner in which the offense was perpetrated, or from the acts of the accused before, during, and after the crime which indicate a common design. The acts of the accused—accosting the victims together while armed, giving chase, carrying out coordinated attacks where each had a different task (e.g., Pedro with a samurai, petitioner and Lando hacking Freddie, Rolly using a stone, Narciso standing guard), and leaving together after the attacks—collectively demonstrated a joint purpose and design. Once conspiracy is proven, the act of one is the act of all, making petitioner equally liable as a principal for the crimes committed pursuant to the conspiracy.