G.R. No. 75530, December 19, 1989
The People of the Philippines, plaintiff-appellee, vs. Vicente Tan, Eddie Tan, and Federico Fajardo, accused-appellants.

FACTS

On March 18, 1986, around 11:30 PM, Rodulfo Hinuctan and his companions were walking home in Iligan City when their path was blocked by appellants Vicente Tan, Eddie Tan, Federico Fajardo, and Meliton Valencia. The group was armed with bladed weapons. Federico Fajardo approached Hinuctan with a bolo. As Hinuctan raised his hands, Vicente Tan stabbed him with a kitchen knife on the right side below the armpit. Hinuctan fell, and Eddie Tan approached, remarking, “He is already dead.” The victim died shortly after at the hospital from the fatal wound.
The accused presented a different version. Eddie Tan testified that he alone stabbed Hinuctan in retaliation for being beaten by the victim earlier that night. He claimed he acted alone and that his brother Vicente and cousin Federico arrived only after the stabbing. Vicente Tan corroborated this, denying involvement and asserting he was drinking elsewhere at the time.

ISSUE

The core issues were: (1) whether conspiracy existed among the three appellants, and (2) whether the killing was qualified by evident premeditation.

RULING

The Supreme Court affirmed the conviction for murder and found both conspiracy and evident premeditation present. On conspiracy, the Court ruled that the appellants’ collective actions demonstrated a unity of purpose and design. They acted in concert by blocking the victim’s path, with Fajardo directly confronting Hinuctan, which facilitated Vicente Tan’s fatal stab. Eddie Tan’s remark after the attack further indicated his complicity and awareness of the common criminal objective. Their coordinated conduct sufficed to establish conspiracy, making each liable for the acts of the others.
Regarding evident premeditation, the Court found it sufficiently proven. The sequence of events showed ample time for cool reflection. After being assaulted by Hinuctan around 10:00 PM, Eddie Tan went to the hospital, secured a medical certificate, retrieved a knife from his home, and then sought out the victim with his companions. Over an hour and thirty minutes elapsed between the initial provocation and the killing. This interval provided adequate opportunity to reconsider, but the appellants persisted, driven by a deliberate plan for revenge. The Court cited jurisprudence stating that evident premeditation exists when the execution of the act is preceded by cool thought and reflection, which was present here. Thus, the killing was murder qualified by evident premeditation. The decision of the Regional Trial Court was affirmed in toto.