G.R. No. L-30038 July 18, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOAQUIN VELEZ, ALEJANDRO VELEZ and ANTONIETO VELEZ, accused, JOAQUIN VELEZ and ALEJANDRO VELEZ, accused-appellants.

FACTS

The case arose from the killing of Narciso Becuna on June 25, 1966, in Catubig, Northern Samar. The victim had been playing a card game called monte in the house of the Velez family. After a prolonged session where Narciso was winning, he insisted on stopping to eat, which the Velez brothers opposed. Joaquin Velez uttered a threat about lives being involved if the game stopped. Narciso and his brother Ernesto, sensing danger, jumped out a window and fled. Outside, they were intercepted by Alejandro Velez, armed with a bolo. As Narciso stepped back, Joaquin appeared from behind and stabbed him in the back with a barbed harpoon. While Joaquin tried to pull the harpoon out, Alejandro stabbed Narciso. Antonieto Velez then arrived and slashed the already fallen victim. Narciso sustained fourteen wounds, two of which were fatal. The brothers were charged with murder.

ISSUE

The primary issue is whether the Velez brothers, particularly appellants Joaquin and Alejandro (the latter having died during appeal), acted in conspiracy to commit murder, thereby holding them equally liable for the crime.

RULING

The Supreme Court affirmed the conviction, finding conspiracy among the Velez brothers. The legal logic rests on the inference of conspiracy from their coordinated conduct before, during, and after the killing. Their actions demonstrated a unity of purpose to kill Narciso. Joaquin’s threat inside the house, Alejandro’s apparent waiting outside armed with a bolo, and the simultaneous armed attack by all three brothers constituted a connected and cooperative effort to achieve the unlawful objective of liquidating the victim. Conspiracy exists when persons aim towards the same unlawful object through acts that are interdependent, indicating concurrence of sentiment, even without proof of an actual meeting.
The killing was qualified by treachery. The mode of attack—ambushing the unarmed victim from different sides with deadly weapons—was deliberately adopted to ensure his death without risk to themselves from any defense he might offer. The circumstance of abuse of superiority was absorbed by treachery. The Court found no evidence of premeditation, as the interval between the threat and the attack was insufficient for cool reflection. With no generic aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed. The civil indemnity was increased to P12,000. The case against Alejandro was dismissed due to his death.