G.R. No. L-14150; October 30, 1961
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO CLARIT and TEOFILO CLARIT, defendants-appellants.

FACTS

The case involves the murder of Orencio Gandamon on the evening of May 1, 1952, in Zamboanga del Norte. The victim and his family were having supper inside a relative’s house when a gunshot was heard from outside, hitting Gandamon. Immediately after the shot, his children, Cristina and Soling, jumped from the house and saw appellants Alejandro and Teofilo Clarit standing nearby, with Alejandro holding a gun. Another son, Salvador, also saw the two appellants from a window. The wife, Liling Subana, later saw them running away. The appellants were known to the family due to a prior land dispute. Alejandro had previously burned Gandamon’s house and was convicted of arson, and both appellants had threatened Gandamon to stop rebuilding on the disputed property.
The appellants presented an alibi, claiming they were in another municipality making copra for one Antonio Lantekse from May 1. However, on cross-examination, Lantekse admitted he was not sure they started work on that specific date, stating his testimony was based on the appellants’ father’s request. The trial court convicted Alejandro as principal and Teofilo as an accomplice, sentencing them accordingly and ordering them to pay indemnity.

ISSUE

The primary issue on appeal is whether the evidence sufficiently establishes the guilt of the appellants and, specifically, whether Teofilo Clarit’s participation constituted that of a principal or merely an accomplice.

RULING

The Supreme Court affirmed the conviction but modified the degree of Teofilo’s participation and the indemnity. The Court found the testimonies of the eyewitnesses—the victim’s wife and children—credible and sufficient to establish guilt beyond reasonable doubt. The witnesses knew the appellants, the night was moonlit, and there were no obstructions, allowing for clear identification. The appellants were seen together at the scene immediately after the gunshot. The alibi was properly rejected due to its weak foundation, as the defense witness himself expressed uncertainty about the crucial date.
On the nature of Teofilo’s participation, the Court ruled he was a principal, not an accomplice. Applying established jurisprudence on conspiracy, the Court held that conspiracy can be inferred from the acts of the accused showing a common design. Here, both appellants had a motive stemming from the land dispute, jointly threatened the victim beforehand, and were seen together at the crime scene immediately after the shooting. Their coordinated presence and actions implied a united purpose to commit the crime. Therefore, Teofilo was equally liable as a principal by conspiracy. The indemnity was uniformly set at P3,000 for each appellant.