G.R. No. 90870; February 5, 1991
Alexander Lozano y Dalisay, petitioner, vs. The Hon. Court of Appeals and People of the Philippines, respondents.

FACTS

On May 9, 1986, at around 10:00 PM, petitioner Alexander Lozano, a construction worker who was a customer of the store owned by spouses Francisco Ocampo, Jr. and Juliana del Rosario, knocked on their door. When Juliana opened it, Lozano entered, and one of his companions held her hand. Francisco rushed to aid his wife, at which point Lozano attempted to stab him with an icepick. A struggle ensued between Francisco and Lozano over the icepick. After they separated, an unidentified companion of Lozano, who was outside the house, shot Francisco. Francisco, though wounded, managed to seek help. Meanwhile, Juliana’s father, Felipe del Rosario, upon hearing shouts and a gunshot, found Juliana lying outside with multiple stab wounds; she died from her injuries.
Patrolman Levy Frias investigated the incident. While Francisco was recovering in the hospital, he provided statements identifying “Alex” (the petitioner) as an assailant. The police located Lozano, and Francisco subsequently identified him in a lineup. Lozano, along with two co-workers, was charged. During trial, Lozano presented an alibi, claiming he was asleep at the construction site at the time of the incident.

ISSUE

Whether the Court of Appeals erred in convicting petitioner of homicide and serious physical injuries based on conspiracy, despite the prosecution not proving he personally killed Juliana or shot Francisco.

RULING

The Supreme Court denied the petition and affirmed the conviction. The legal logic centers on the existence of conspiracy. The Court held that conspiracy exists when two or more persons come to an agreement to commit a felony and decide to commit it. Direct proof of a prior agreement is not indispensable; conspiracy can be inferred from the conduct of the accused before, during, and after the commission of the crime, indicating a common purpose.
In this case, the acts of Lozano—barging into the house simultaneously with a companion, the companion holding Juliana, and Lozano immediately attempting to stab Francisco when he intervened—demonstrate concerted action toward a common criminal objective. These synchronized acts provided sufficient basis for the appellate court to conclude that Lozano and his unidentified companions acted in conspiracy. Consequently, under the principle of collective criminal liability, each conspirator is liable for the acts of the others in furtherance of the conspiracy, regardless of the extent of each one’s direct participation. Therefore, Lozano is equally liable for the homicide of Juliana and the serious physical injuries inflicted upon Francisco, even if the fatal stab wounds and the gunshot were directly inflicted by his companions. The Court also modified the civil indemnity, increasing the award for Juliana’s death to P50,000.00 in accordance with prevailing jurisprudence.