G.R. No. 94065 , December 2, 1991
Roberto Siton y Ensalada, petitioner, vs. Hon. Court of Appeals and People of the Philippines, respondents.

FACTS

On February 9, 1985, a free-for-all fight erupted in Sta. Ana, Manila, between two groups. One group included barangay tanod Norberto Notar, his nephew Joey Calip, Andres Borbon, and petitioner Roberto Siton. The other group, which appeared to be drunk, was led by Roylan Holgado. The altercation began after an exchange of words between Notar and Holgado. During the melee, Holgado was stabbed and later died, while Notar also sustained a stab wound. Prosecution witness Bernardo Ferrer testified that he saw Borbon hit Holgado with wood, Siton stab him with an icepick on the hip, and Calip stab him with a kitchen knife. The defense presented witnesses who described a chaotic brawl and offered an alibi for Siton, claiming he was in Cainta, Rizal, at the time.
The Regional Trial Court convicted Siton of Homicide, finding conspiracy among the group members. The Court of Appeals affirmed the conviction, upholding the finding of conspiracy based on their collective assault on Holgado during the fight.

ISSUE

Whether or not conspiracy can be deduced from the participants’ actions in a spontaneous free-for-all fight.

RULING

The Supreme Court reversed the appellate court’s decision and modified the conviction. It held that conspiracy cannot be presumed from a general free-for-all fight. Conspiracy requires a clear showing of a common criminal design and concerted action toward a single criminal objective. In a spontaneous, chaotic melee involving multiple individuals from opposing groups, the actions of the participants are typically driven by reflex and the immediate exigencies of the fight, not by a pre-conceived plan to kill a specific person.
The Court emphasized that to hold a participant liable for the fatal act of another, conspiracy must be proven as clearly and convincingly as the crime itself. The evidence merely established that Siton inflicted a non-fatal stab wound on Holgado’s hip. There was no proof that Siton and his companions had a prior agreement to kill Holgado or that Siton’s specific act was in direct furtherance of a common purpose to kill. Consequently, Siton is liable only for his own individual acts. He was found guilty of Less Serious Physical Injuries for the wound he personally inflicted, which would have incapacitated the victim for more than ten days. The penalty was modified accordingly.