G.R. No. L-1393; February 1, 1949
EL PUEBLO DE FILIPINAS, plaintiff-appellee, vs. RAFAELA GIRON y GATDULA, ET AL., defendants. TOMAS CANLAS y GARCIA, appellant.

FACTS

Appellant Tomas Canlas, along with Rafaela Giron and Jose Estrada, was charged with the murder of Patrocinio San Agustin. Estrada pleaded guilty and was sentenced. Giron and Canlas were convicted as co-principals and sentenced to reclusion perpetua. The evidence established that Giron, the victim’s lover, wanted him killed due to mistreatment and to prevent him from registering a jeep in his name. She offered Estrada P20,000 through Canlas. Canlas repeatedly encouraged and convinced Estrada to accept the offer, assuring him of protection. On the night of the crime, Giron provided details of the plan, and Estrada shot the sleeping victim. Canlas accompanied Estrada to the meeting with Giron to finalize the plan and ensure Estrada’s participation.

ISSUE

Whether appellant Tomas Canlas is liable as a co-principal by induction for the crime of murder.

RULING

Yes. The Supreme Court affirmed the conviction. Canlas is liable as a co-principal by induction under Article 17 of the Revised Penal Code. His acts of recruiting Estrada, repeatedly persuading him to accept the murder offer, and accompanying him to finalize the plan were the efficient cause of the crime. His inducement was made with the intention of achieving the criminal result. His defense of alibi and claim that he was merely helping Estrada find employment as a driver were unconvincing and contradicted by the evidence. His presence at the late-night meeting was integral to ensuring the plan was carried out. The uncorroborated testimony of Estrada was admissible, as no timely objection was raised in the trial court, and it satisfied the court of Canlas’s guilt beyond reasonable doubt.

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