GR 47221; (August, 1941) (Digest)
G.R. No. 47221 ; August 11, 1941
CIPRIANO OFIASA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Cipriano Ofiasa, along with Luis Estacio, Eugenio Carpio, Alejandro Carpio, and Lazaro Carpio, was charged with murder in the Court of First Instance of La Union for the death of Gregorio Ramirez. All were found guilty and sentenced. On appeal, the Court of Appeals acquitted Luis Estacio and Eugenio Carpio but affirmed the conviction of Cipriano Ofiasa, Alejandro Carpio, and Lazaro Carpio. Only Cipriano Ofiasa appealed to the Supreme Court via certiorari.
The factual findings of the Court of Appeals, accepted as conclusive, established that on May 11, 1938, while fishing, Ofiasa had a dispute with Fernando Ramirez, whom he threatened and later slapped ashore. Gregorio Ramirez (Fernando’s father), who witnessed the slapping, approached and asked Ofiasa why he did it. At that moment, Luis Estacio and Eugenio Carpio (who were later acquitted) held Gregorio by the arms. While Gregorio was thus restrained, Cipriano Ofiasa, Lazaro Carpio, and Alejandro Carpio beat him with oars until he fell. Gregorio died on May 13, 1938, from cerebral hemorrhage caused by the blows. The Court of Appeals found the crime qualified as murder due to the accused taking advantage of superior strength.
ISSUE
1. Whether the crime committed was murder.
2. Whether conspiracy existed among the accused, and consequently, the extent of petitioner Cipriano Ofiasa’s individual criminal liability.
RULING
1. On the Nature of the Crime: The Supreme Court found no fault with the ruling of the Court of Appeals that the crime was murder, qualified by the circumstance of the accused taking advantage of their superior strength.
2. On Conspiracy and Individual Liability: The Supreme Court held that conspiracy was not established. There was no direct evidence of an agreement to commit a felony, and a prior plot to kill Gregorio was deemed unlikely as Gregorio was not involved in the initial dispute between Ofiasa and Fernando. Since conspiracy was not proven, each accused is liable only for his own acts. The Court found the appellate court’s statement—that the deceased died from injuries inflicted by Ofiasa, Lazaro Carpio, and Alejandro Carpio—insufficiently precise regarding the individual contributions of each.
The Supreme Court remanded the case to the Court of Appeals for a determination of petitioner Cipriano Ofiasa’s individual liability based on his specific participation in the crime and for the imposition of the corresponding penalty.