US vs Bautista 6 Phil 581 (1906)

Peoeple vs Vengco 127 SCRA 242

Nature: Appeal from the judgment of the (1984)
Manila CFI
Nature: Appeal from the judgment of the
Facts: In 1903 a junta was organized and a Manila CFI
conspiracy entered into by a number of
Filipinos in Hongkong, for the purpose of Facts:
overthrowing the government of the United Constantino Leneses, Leon David, and three
States in the Philippine Islands by force of others (who did not file for an appeal; includes
arms and establishing a new government. Edwin Vengco) were found GUILTY of
Francisco Bautista (1), a close friend of the MURDER of Charlie Celadea, who died 24
chief of military forces (of the conspirators) August 1967. Both were sentenced of
took part of several meetings. Tomas Puzon reclusion perpetua.
(2) held several conferences whereat plans
are made for the coming insurrection; he was Issue: WON conspiracy for murder was
appointed Brigadier-General of the Signal present among the accused.
Corps of the revolutionary forces. Aniceto de
Guzman (3) accepted some bonds from one Held: Yes. AFFIRMED with modification. The
of the conspirators. accused are (still) GUILTY of MURDER and
The lower court convicted the three men of are charged of recluson perpetua. they have
conspiracy. Bautista was sentenced to 4 years to pay the heirs of the deceased in the sum of
imprisonment and a P3,000 fine; Puzon and P30,000 as modified from the P12,000 as
De Guzman to 3 years imprisonment and decided by the lower court. There was
P1,000. conspiracy between Leneses, David, and the
three others. This conspiracy among them is
Issue: WON the accused are guilty of discernable from the way they assaulted
conspiracy. Celadea, as well as their conduct sometime
before and immediately after the stabbing (eg.
Held: Judgment for Bautista and Puzon Vengco chased Celadea and threw bottles at
CONFIRMED. Judgment for de Guzman him three or four nights prior to Celadeas
REVERSED. Yes, Bautista and Puzon are death; David left Manila for Cavite where he
guilty of conspiracy. Bautista was fully aware hid himself until he was arrested) shows that
of the purposes of the meetings he they had agreed to kill him. Conspiracy may
participated in, and even gave an assurance be inferred though no actual meeting among
to the chief of military forces that he is making them is proven. The fact that they were
the necessary preparations. Puzon voluntarily accomplishing the same unlawful act, each
accepted his appointment and in doing so doing a part so that their acts, although
assumed all the obligations implied by such apparently independent, were proven to be
acceptance. This may be considered as an connected and cooperative, indicates a
evidence of the criminal connection of the closeness of personal association and
accused with the conspiracy. concurrence of sentiment.
However, de Guzman is not guilty of Also, accused Leon David, even if he did not
conspiracy. He might have been helping the assault the victim at the scene of the crime (as
conspirators by accepting bonds in the testified by a credible witness) may be guilty
bundles, but he has not been aware of the as well since his hiding right after the crime
contents nor does he was, in any occasion, until his arrest is a circumstance highly
assumed any obligation with respect to those indicative of his guilt.
bonds.
Note: see RPC Art. 136: Crimes against public
order: conspiracy and proposal to commit
coup d etat, rebellion or insurrection.
People vs Valdez, 159 SCRA 153
(1988)
People vs Ecober 157 SCRA 541
Facts: On 7 June 1977, Eleno Maquiling (1988)
was shot while at the yard of their house.
Esmenia, the victims mother, and Dionisio, Facts: Escober, Punzalan and 3 others were
the victims brother, saw Danilo Valdez and accused of committing robbery with homicide
Simplicio Orodio running down the hill away in Balintawak, QC on Dec. 3, 82. Mr. Vicenta
from the bamboo groves. The lower court Chuas office was robbed of P5K and his
decided that the accused are guilty of children were stabbed to death. Escober was
murder, imposing upon each them the company guard & alleged mastermind.
capital penalty of death, damages and Abuyen was former guard relieved due to
absence & found sleeping on duty.
costs.
Issues:
Issue: WON there was a conspiracy
1. WON RTC conformed with Art. 9,
between the accused in killing Maquiling. Sec 9 of the Constitution
Held: Yes. Judgment AFFIRMED. But under No. Art 9. Sec 9 states that decision should
the 1987 Constitution, in view of the have facts, not present in decision.
abolition of capital punishment, the Generalizations and conclusions without
applicable penalty is reclusion perpetua. detailed facts as basis. Appellate court cant
The evidence of the prosecution is more check if findings were sufficient and logical.
than adequate to sustain the finding of Justice and fairness over speed. People v.
conspiracy between the two accused. It Banayo: decision should show evidence, facts
does not matter that the prosecution has based on evidence and supporting
failed to show who was between the two jurisprudence and authority
who actually pulled the trigger that
consequently killed the child. They are liable 2. WON Escober is guilty
as co-conspirators since any act of a co-
conspirator become the act of the other No. Opening of gate is normal when someone
regardless of the precise degree of knocks especially if you know him. He might
participation in the act. have lacked better judgment or laxity in
Also, there was presence of treachery, performance of duties though. The firing of the
because of the circumstances that the crime gun as a ritual to avoid suspicion is too risky a
ritual. It can kill. 5-10 minutes too short a time
was done at night time and that the accused
to plan a conspiracy. Abuyen even asked
hid themselves among the bamboo. Evident
Punzalan to kill Escobar. Then Abuyen
premeditation is also an aggravating
pointed the gun at Escobar and asked
circumstance (the accused had planned to Punzalan to tie him; he also tries to shoot him.
kill the victims some days before). Offering the information that he was not hit
was also just to assure employer who seemed
concerned. Mrs Chuas statement may have
been confused cause it was taken last.
Perhaps she forgot details due to agitation.

3. WON Punzalan is guilty

Yes. Extrajudicial confession is inadmissible

because it was not properly performed and
was without counsel. Conspiracy was proven.
He was fetched and he fled with suspects. He
shouldve gone to the police if innocent.
People vs. Rogel: Homicide through robbery,
all principals in robbery are liable for homicide Li vs People, 427 SCRA 217 (2004)
unless they tried preventing it.
Facts:
A petty argument evolved into a street brawl.
People vs Elijorde , 306 SCRA 188 (1999) After the dust had settled, Christopher Arugay
lay dying from multiple stab wounds, while his
Facts: Elijorde and Punzalan charged with neighbor, Kingstone1 Li ("Li"), staggered
murder of Eric Hierro. Altercation began injured, with hack wounds on his head.
when Hierro told Meneses not to touch him Shortly before his death, Arugay was watching
cause his clothes will get dirty. Fist fight television at home with his sisters. Peering
occurred. Hierro hid. After 30 mins he went through the window, they saw Li and Eduardo
out to go home but was attacked again & Sangalang taking a bath completely naked.
stabbed to death. The two were facing the house of the
Arugays. An incensed Arugay went out the
Issue: WON Punzalan is liable as house where he was met by Li, now wearing
conspirator? briefs and carrying a baseball bat. Li struck
Arugay on the head with the bat, causing
Held: No. Punzalan acquitted. Elijorde Arugay to fall. Li ran back to his house. Li re-
guilty. In People v. Lug-aw, conspiracy emerged, this time with a knife. Li then
should be proven through clear and stabbed Arugay once. Arugay hit Li with the
convincing evidence. In People v. De bolo. Li passed out.Upon regaining
Roxas, it is established that it must be consciousness, Li tried to crawl back to his
proven that he performed overt act to house but Ronald Tan hit him at the back of
pursue completely. Visbal testified that only his left ear with a baseball bat. At this point in
time, Eduardo Sangalang, who was then also
Elijorde chased Hierro. Punzalans only
present stabbed the deceased several times
participation was kicking which does not
at least six times.
prove that he might have known Elijordes
evil design or intent to kill. In People v. RULING:
Agapinay, there was no proof that the
accused knew about the deadly weapon A conviction premised on a finding of
and that it was to be used to stab victim. In conspiracy must be founded on facts, not on
the case at bar, Punzalan desisted from mere inferences and presumption. It is worth
acts of aggression and did nothing to assist noting that while conspiracy was alleged in
Elijorde in committing murder the Information against Li, the prosecution
devoted its efforts to prove that Li had actually
inflicted the stab wounds on Sangalang,
tagging him as a direct participant in the
crime. Thus, there seems to be no evidence
that would directly establish the fact that Li
and Sangalang had come into an agreement
to commit a common felony. Any conclusion
that there was a conspiracy will have to be
drawn inferentially, as the RTC did.
It is not necessary to prove a previous
agreement to commit a crime if there is proof
that the malefactors have acted in concert and
in pursuance of the common objectives. Direct
proof is not essential to show conspiracy since
it is by its nature often planned in utmost
secrecy and it can seldom be proved by direct
evidence.52 Conspiracy may be inferred from enterprise in which he has a pecuniary
the acts of the accused themselves when interest may be convicted, together with his
such point to a joint purpose and design. spouse, of violation of that same provision
Complicity may be determined by concert of premised on his mere possession of such
action at the moment of consummating the interest.
crime and the form and manner in which Accused Edgar Y. Teves, Mayor of Valencia,
assistance is rendered to the person inflicting Negros Oriental, while in the performance
the fatal wound.Moreover, it appears that the and taking advantage of his official
fight involved two distinct phases. The first functions, and conspiring and confederating
phase commenced when Li, without sufficient
with his wife, Teresita Teves, did then and
provocation, assaulted Arugay with the
there willfully, unlawfully and criminally
baseball bat. Lis participation in this phase,
cause the issuance of the appropriate
albeit as a solitary actor, was indubitably
established. Sangalangs participation, much business permit/license to operate the
less his physical presence during this phase, Valencia Cockpit and Recreation Center in
was not established at all. In the second favor of one Daniel Teves, said accused
phase, Sangalang was the main actor. Li was Edgar Y. Teves having a direct financial or
incapacitated by then. Clearly, the existence pecuniary interest therein considering the
of conspiracy should be ruled out. fact that said cockpit arena is actually
The only injury attributable to Li is the owned and operated by him and accused
contusion on the victims right arm that Teresita Teves. The evidence for the
resulted from Li striking Arugay with a prosecution has established that petitioner
baseball bat. When there is no evidence of Edgar Teves owned the cockpit in question
actual incapacity of the offended party for he turned over the management of the
labor or of the required medical attendance, cockpit to Mrs. Teresita Z. Teves for the
the offense is only slight physical reason that [he] could no longer devote a
injuries.Careful scrutiny of the evidence full time as manager of the said entity due to
reveals that the criminal culpability of other work pressure.
Kingstone Li in the death of Christopher
Arugay was not established beyond RULING:
reasonable doubt. Unfortunately, the person
who is responsible for the death apparently Petitioner Teresita Teves must, be acquitted.
remains at large. Yet absent any clear
The charge against her is conspiracy in
showing of conspiracy, as in this case,
causing the issuance of the appropriate
Kingstone Li cannot answer for the crime of
business permit/license to operate the
Eduardo Sangalang.
Valencia Cockpit and Recreation Center.
The Decision of the Court of Appeals is For this charge, she was acquitted. But as
MODIFIED. Petitioner Kingstone Li is discussed earlier, that charge also includes
ACQUITTED of the charge of Homicide for conspiracy in the possession of prohibited
lack of evidence beyond reasonable doubt. interest.
However, he is found GUILTY of the crime of Conspiracy must be established separately
SLIGHT PHYSICAL INJURIES. from the crime itself and must meet the
same degree of proof, i.e., proof beyond
reasonable doubt. While conspiracy need
Teves vs. Sandiganbayan GR 154182 not be established by direct evidence, for it
may be inferred from the conduct of the
Facts: accused before, during, and after the
The pivotal issue in this petition is whether a commission of the crime, all taken together,
public official charged with violation of Anti- the evidence must reasonably be strong
Graft and Corrupt Practices Act, for unlawful enough to show community of criminal
intervention, in his official capacity, in the design. Certainly, there is no conspiracy in
issuance of a license in favor of a business just being married to an erring spouse. For
a spouse or any person to be a party to a render her equally liable as her husband. If
conspiracy as to be liable for the acts of the ever she did those acts, it was because she
others, it is essential that there be herself was an owner of the cockpit. Not
intentional participation in the transaction being a public official, she was not
with a view to the furtherance of the prohibited from holding an interest in
common design. Except when he is the cockpit. Prudence, however, dictates that
mastermind in a conspiracy, it is necessary she too should have divested herself of her
that a conspirator should have performed ownership over the cockpit upon the
some overt act as a direct or indirect effectivity of the LGC of 1991; otherwise, as
contribution in the execution of the crime stated earlier, considering her property
planned to be committed. The overt act relation with her husband, her ownership
must consist of active participation in the would result in vesting direct prohibited
actual commission of the crime itself or of interest upon her husband.
moral assistance to his co-conspirators. In criminal cases, conviction must rest on a
We find no sufficient evidence that petitioner moral certainty of guilt. The burden of proof
Teresita Teves conspired with, or knowingly is upon the prosecution to establish each
induced or caused, her husband to commit and every element of the crime and that the
the second mode of violation of Section 3(h) accused is either responsible for its
of the Anti-Graft Law. The acts of petitioner commission or has conspired with the
Teresita Teves can hardly pass as acts in malefactor. Since no conspiracy was
furtherance of a conspiracy to commit the proved, the acquittal of petitioner Teresita
violation of the Anti-Graft Law that would Teves is, therefore, in order.