G.R. No. L-10677; September 30, 1959
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME CANARE, ET. AL., defendants-appellants; AMADO BONDOC, BERNARDO OLAYA AND ALEJANDRO CANARE, defendants-appellants.

FACTS

On the afternoon of February 4, 1954, Anastacio Valencia was shot twice inside his house in Abucay, Bataan. He was later taken to the hospital where he died. Before his death, he made dying declarations to his wife, Pilar Renosa, and to investigating officers, identifying Jaime Canare (bodyguard of Representative Nuguid) and “Berning” (Bernardo Olaya) as the persons who shot him. The autopsy confirmed two fatal gunshot wounds. An information for murder was filed against Jaime Canare, Bernardo Olaya, Alejandro Canare, Amando Bondoc, Nicanor Santos, and one Loring, alleging conspiracy. Jaime Canare died before arraignment. The remaining three defendants (Amando Bondoc, Bernardo Olaya, and Alejandro Canare) pleaded not guilty. After the prosecution rested, the defendants moved for dismissal, submitted the case for judgment without presenting evidence, and were convicted by the trial court, which found conspiracy and sentenced each to life imprisonment. They appealed.

ISSUE

Are the appellants (Amando Bondoc, Bernardo Olaya, and Alejandro Canare) criminally responsible for the murder of Anastacio Valencia, based on the evidence presented by the prosecution?

RULING

No. The Supreme Court reversed the trial court’s judgment and acquitted all appellants.
* Regarding Conspiracy: The Court found the evidence insufficient to prove conspiracy among the defendants. The circumstances from Alejandro Canare’s unsigned extrajudicial statement could only bind him, if proven voluntary, but not his co-defendants. Even considering those circumstances, they did not establish conspiracy. Each defendant’s guilt had to be determined individually.
* Regarding Amando Bondoc: The evidence against him consisted solely of the widow’s testimony that she saw him at his window asking the men pushing a jeep, “Is it through? Is it finished already?” and hearing a reply, “It is already finished. It is already done.” His affidavit stated he was drinking elsewhere and was later asked to repair a jeep. The Court found this evidence insufficient to convict him beyond reasonable doubt.
* Regarding Bernardo Olaya: The only evidence against him was the victim’s dying declaration that Jaime Canare was accompanied by Bernardo Olaya. The Court held this alone did not prove Olaya had knowledge of Canare’s plan. Olaya’s own statement—that he was merely asked to call Valencia, and that Canare, who was behind him, suddenly shot Valencia—nullified any implication of prior knowledge or complicity.
* Regarding Alejandro Canare: The evidence did not disclose any act linking him to the commission of the crime, either before, during, or after the incident. The evidence against him was found insufficient for conviction beyond reasonable doubt.
The Court concluded the prosecution failed to establish the criminal liability of the appellants.