G.R. No. L-33522. June 24, 1983.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARCIANO LOJO and JOSE MENDOZA, JR., accused, JOSE MENDOZA, JR., defendant-appellant.

FACTS

The case stemmed from the fatal shooting of brothers Rodolfo and Romeo Dimaano by Marciano Lojo on the evening of May 25, 1969, in Barrio Lodlod, Lipa City. The incident began earlier that afternoon when Lojo and Romeo Dimaano had a physical altercation inside a jeep driven by appellant Jose Mendoza, Jr., who intervened to pacify them. That evening, after hearing Romeo complain about being hit by Lojo, Rodolfo approached to pacify his brother. Lojo arrived, drew a gun, and shot Rodolfo from behind. He then shot Romeo and continued firing at Rodolfo as he lay on the ground. After the shooting, Lojo fled to Mendoza’s nearby house. Appellant Mendoza then drove Lojo away from the scene in his jeep. Witnesses heard Mendoza urge, “sakay kayo Kakang Siano, baka tayo’y abutin pa.” Lojo was eventually apprehended in Rosario, Batangas, months later.
The trial court convicted Marciano Lojo as principal for the murder of Rodolfo (qualified by treachery) and the homicide of Romeo. It convicted Jose Mendoza, Jr. as an accessory after the fact to the murder. Lojo withdrew his appeal, leaving only Mendoza’s conviction for review. Mendoza argued he had no knowledge of the crimes when he assisted Lojo and that the evidence did not indubitably prove such awareness, rendering his conviction based on conjecture.

ISSUE

Whether the prosecution proved beyond reasonable doubt that Jose Mendoza, Jr. is guilty as an accessory after the fact to the crime of murder.

RULING

Yes, the conviction is affirmed. The Court found the evidence sufficient to establish all elements of being an accessory after the fact under Article 19 of the Revised Penal Code. First, Mendoza had knowledge of the crime. He was present during the earlier quarrel between Lojo and Romeo Dimaano and heard Romeo’s threat of vengeance. Immediately after hearing gunshots near his house that evening, Lojo arrived at his residence. The natural and probable reaction would have been to inquire about the commotion, especially given the prior hostile incident. His claim that he drove Lojo to surrender at the police station, without any inquiry, was deemed not credible, as they instead fled towards Rosario.
Second, Mendoza did not participate as a principal or accomplice in the killing itself. Third, he subsequently assisted the principal by facilitating his escape. By driving Lojo away from the crime scene with urgency, as evidenced by his exhortation to board quickly, he provided the means for evasion. The totality of circumstances—his prior knowledge of the animosity, the proximity of the gunshots, Lojo’s immediate arrival, and the hurried departure—logically leads to the conclusion that Mendoza was aware Lojo had committed a crime and intentionally helped him escape. Therefore, the trial court correctly convicted him as an accessory after the fact.