GR L 41605; (August, 1985) (Digest)
G.R. No. L-41605 August 19, 1985
ROGELIO PRING and ALBERTO (ROBERTO) ROXAS, petitioners, vs. THE HONORABLE COURT OF APPEALS AND THE PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners Rogelio Pring and Alberto Roxas, along with others, were charged with Murder for the death of Loreto Navarro. The prosecution evidence established that a prior altercation occurred between the group of accused Angelito Naungayan and the group of the deceased. The following day, the accused, including petitioners, went to the Abucay Canteen. Upon seeing Navarro’s group, some entered the canteen while others remained outside, after which a coordinated assault ensued. During the fight, a co-accused, David Ravago, fatally stabbed Navarro. Petitioners were actively involved in the melee, assaulting other members of Navarro’s group with a bench and a piece of wood. The trial court convicted them of Homicide, a decision affirmed by the Court of Appeals.
ISSUE
Whether the petitioners can be held criminally liable for the death of Loreto Navarro despite not having inflicted the fatal stab wounds, based on a finding of conspiracy.
RULING
Yes. The Supreme Court affirmed the conviction, ruling that conspiracy was sufficiently established. The legal logic hinges on the principle of collective criminal liability arising from conspiracy. Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. It may be inferred from the conduct of the accused before, during, and after the commission of the crime, indicating a common purpose and concerted action.
The Court found that the acts of the petitioners and their co-accused—their coordinated approach to the canteen, their simultaneous attack on Navarro’s group, and their use of various weapons like a stool and wood—demonstrated a united purpose to assault and inflict harm. This common design to commit aggression made them conspirators. Consequently, under the doctrine of conspiracy, each conspirator is liable for the acts of the others in furtherance of the common criminal objective. The fact that the fatal wound was inflicted by Ravago with a knife, while petitioners used other means, does not exonerate them. The Court cited precedent stating that conspirators are liable for acts done by co-conspirators even if the specific mode of attack differs, provided the act is a consequence of the execution of the common design. The aggression, though initially directed at other group members, was part of a single felonious undertaking, making all participants responsible for the lethal result. The factual findings of the lower courts, accorded great weight, conclusively proved this joint criminal enterprise.