GR 230778; (July, 2019) (Digest)
G.R. No. 230778 July 22, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JUAN CREDO y DE VERGARA and DANIEL CREDO y DE VERGARA, Accused-Appellants
FACTS
Accused-appellants Juan and Daniel Credo were charged with Murder for the death of Antonio Asistin and Frustrated Murder for the stabbing of his wife, Evangeline. The prosecution alleged that on March 16, 2004, at the Asistin residence in Quezon City, two unidentified men attacked Evangeline inside their computer shop. During the assault, Daniel, Evangeline’s nephew and an assistant at the shop, was present but did not help her. After the assailants fled, Evangeline saw Antonio at the gate with multiple stab wounds. Witnesses testified that Daniel carried Antonio and then dropped him, causing his head to hit the ground. Antonio died from his injuries. Juan was also separately charged with illegal possession of a firearm under P.D. 1866 for having a homemade shotgun.
ISSUE
The core issue is whether the accused-appellants are guilty beyond reasonable doubt of the crimes charged, particularly whether conspiracy was established to hold them liable as co-conspirators.
RULING
The Supreme Court affirmed the convictions. The Court found conspiracy was sufficiently proven by the appellants’ collective and coordinated actions leading to the crimes. Daniel’s presence during the attack on Evangeline, coupled with his failure to render aid and his subsequent act of dropping the wounded Antonio, demonstrated a community of criminal purpose with the direct assailants. His actions were not those of an innocent bystander but of a participant ensuring the fatal outcome. For Juan, his act of providing the assailants with a firearm established his indispensable cooperation in the execution of the crimes. The Court ruled that conspiracy can be inferred from the conduct of the accused before, during, and after the commission of the crime, showing they acted in concert towards a common goal. The positive identification and credible testimony of Evangeline, who had no ill motive to falsely accuse her own nephews, prevailed over the appellants’ defenses of denial and alibi. The qualifying circumstance of treachery was also correctly appreciated, as the attack was sudden and unexpected, rendering the victims unable to defend themselves. Juan’s separate conviction for illegal possession of a firearm under P.D. 1866 was likewise upheld.