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