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FACTS
ISSUE
RULING
According to Article 14 of the Revised Penal Code, and in connection with Article 13,
defines an accomplice to be the one who does not take direct part in the commission of
the act who does not force or induce other to commit it, nor cooperates in the commission
of the act by another act without which it would not have been accomplished, yet
cooperates in the execution of the act by previous or simultaneous actions. In the case at
bar, no cooperation was made by Silvestre, since the complicity or involvement requires
a certain degree of cooperation whether moral through advice, encouragement or
agreement or material, through external acts. In Silvestre’s case, her mere presence and
simultaneous acts do not constitute the cooperation and therefore does not make her
qualify to be an accomplice, as stated and required by Article 14 of the Penal
Code.