G.R. No. L-26898 & L-26899, January 16, 1973
The People of the Philippines, plaintiff-appellee, vs. Apolonio Enomar, et al., defendants-appellants.

FACTS

In Criminal Case No. OZ-204, Apolonio Enomar and his sons Raymundo, Pablo, Basilio, and Leon were charged with the murder of Paulino Aballe, their uncle. The incident occurred on July 25, 1964, after a benefit dance. Three days prior, Paulino had rebuked Leon over a carabao damaging his crops. On the night of the dance, as Paulino left the venue with his daughters, he was met by Leon, who stabbed him with a hunting knife, causing his death. Leon surrendered and initially claimed self-defense. The prosecution alleged conspiracy among all accused, citing their presence at the dance where Apolonio’s radio-phonograph was used and their familial relationship.
In a separate Criminal Case No. OZ-203, Apolonio Enomar was charged with illegal possession of a firearm and ammunition, which was wrested from him by a relative of the victim during the commotion following the stabbing. After both parties filed briefs, Leon Enomar withdrew his appeal, leaving the appeals of Apolonio, Raymundo, Pablo, and Basilio regarding the murder conviction.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that appellants Apolonio, Raymundo, Pablo, and Basilio Enomar conspired with Leon to commit murder.

RULING

The Supreme Court acquitted Apolonio, Raymundo, Pablo, and Basilio of murder but affirmed Apolonio’s conviction for illegal possession of firearm. The Court found no sufficient evidence of conspiracy. The mere presence of the appellants at the dance and their familial tie to the principal assailant, Leon, do not constitute conspiracy, which requires proof of a prior agreement and concerted action to commit the crime.
The legal logic centers on the standard of proof for conspiracy. The Court emphasized that conspiracy must be established as clearly as the crime itself, not by mere conjecture. Key circumstances negated conspiracy: first, the appellants’ female family members remained at the scene, which they would likely have removed if a planned killing was imminent; second, Apolonio sought refuge in a barrio captain’s house and only learned of the stabbing from him, indicating no prior knowledge; and third, other appellants similarly fled in fear, suggesting they did not anticipate the event or any reprisal. The confusion after the stabbing and potential witness biases further rendered the evidence unreliable. Thus, the murder charge was not proven beyond reasonable doubt.
Regarding the firearm charge, the Court found the evidence straightforward and conclusive. Apolonio did not contest the lack of a license for the revolver and ammunition. His guilt for illegal possession was therefore affirmed based on the clear facts and applicable law. The decision in the murder case was reversed for the four appellants, while the conviction for illegal possession against Apolonio was upheld.