G.R. No. L-26731 June 30, 1971
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGELINO PUDPUD, ELEUTERIO CUBELO and PASTOR CERILIGA, defendants-appellants.

FACTS

The appellants, Angelino Pudpud, Eleuterio Cubelo, and Pastor Cereligia, along with Icasiano Pudpud, were convicted of murder and attempted murder. The crimes stemmed from a long-standing land dispute between the Pudpud family and the victim, Federico Postrero, their first-degree cousin. Postrero had successfully litigated for possession of the land, leading to deep-seated resentment. On March 26, 1964, Icasiano Pudpud threatened to kill Postrero, and an arson incident occurred. The following day, Postrero, accompanied by Alfonso Milagrosa and others, went to file criminal complaints for grave threats and arson.
On their return trip by carabao on the evening of March 27, 1964, along a trail, the group was ambushed. A shotgun blast from the side of the road fatally struck Alfonso Milagrosa and caused Postrero to fall. Immediately after the shot, the four accused emerged from the cogon grasses. Icasiano Pudpud was armed with a shotgun and a bolo, while appellants Angelino Pudpud, Eleuterio Cubelo, and Pastor Cereligia were each armed with bolos. Icasiano then approached and hacked the fallen Milagrosa.

ISSUE

Whether appellants Angelino Pudpud, Eleuterio Cubelo, and Pastor Cereligia are liable as co-conspirators for the murder of Alfonso Milagrosa and the attempted murder of Federico Postrero, despite not having fired the fatal shot.

RULING

Yes, the appellants are liable as co-conspirators. The Supreme Court affirmed the conviction, holding that conspiracy was sufficiently established. The legal logic centers on the principle that conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. Proof of a prior agreement is not essential; conspiracy can be inferred from the conduct of the accused before, during, and after the crime, indicating a common design or unity of purpose.
The Court found such unity of purpose present. The appellants, armed with bolos, were lying in wait with Icasiano Pudpud, who was armed with a shotgun. Their simultaneous emergence from concealment immediately after the ambush, all armed and positioned to attack, demonstrated concerted action towards the common objective of killing Postrero. The fact that the shotgun blast hit Milagrosa, who was riding with Postrero, does not absolve the appellants. When conspiracy is established, the act of one is the act of all. All conspirators are equally liable for the crimes committed in pursuance of the conspiracy, including the natural and probable consequences thereof. The ambush was a direct result of their collective plan, and the killing of Milagrosa was a foreseeable outcome of the armed attack on the group. Therefore, all accused, including the three appellants, are guilty as co-principals.