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 remarked, “He is already dead.” The victim was rushed to the hospital but died shortly thereafter from the fatal wound.
The accused presented a different version. Eddie Tan testified that he alone stabbed Hinuctan in retaliation for an earlier beating he suffered. He claimed he acted alone and that his brother Vicente and cousin Federico arrived only after the stabbing. Vicente Tan corroborated this, stating they were elsewhere drinking and only came upon the scene after the incident.

ISSUE

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

RULING

The Supreme Court affirmed the conviction for murder, finding 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 to block the victim’s path, with Fajardo directly confronting Hinuctan, which facilitated Vicente Tan’s fatal attack. Eddie Tan’s presence and his remark after the stabbing confirmed his participation in the common criminal intent. Their individual denials and Eddie’s claim of sole responsibility were rejected in light of the positive and credible identification by prosecution eyewitnesses, who had no improper motive to testify falsely.
Regarding evident premeditation, the Court found the element sufficiently established. The evidence showed that over an hour and a half elapsed from the time Eddie Tan was assaulted by the victim until the killing. During this interval, Eddie secured medical treatment, procured a knife from his home, and enlisted the help of his co-accused to locate Hinuctan. This period provided adequate time for cool reflection and for the appellants to deliberate on their plan for revenge. The Court cited jurisprudence stating that evident premeditation exists when the execution of the criminal act is preceded by cool thought and reflection, and it is present where the killing is an act of revenge conceived well before its perpetration. The appellants’ actions were deemed motivated by a spirit of lawlessness and deliberate retaliation, not by sudden impulse. Therefore, the qualifying circumstance of evident premeditation was properly appreciated by the trial court.