G.R. No. 74048 - People vs. Cruz

The case involves accused-appellant Rolando Cruz, alias Tikboy, charged with murder as co-principal in the killing of Jesus Baang.
The incident occurred on November 25, 1983, in Malabon, Metro Manila.
Rolando Cruz was implicated as a co-conspirator and principal by inducement despite eyewitness accounts primarily identifying another individual.

Victim: Jesus Baang, a 36-year-old married fisherman, was fatally shot.
Wounds: The autopsy by Dr. Ricardo Ibarrola revealed three gunshot wounds – at the head, chest, and back – with two being fatal.
Circumstances: Eyewitnesses reported that Baang was shot consecutively; initially from behind, then while he turned around, and finally a coup de grace to the head.

Danilo Soriano testified that he witnessed the shooting and noted that Rading Sason was the apparent assailant.

Soriano mentioned that he did not see Rolando Cruz during the actual shooting but observed him later at an alley near the crime scene.

Renato Ramirez corroborated the sequence of events, describing the approach of Sason, the shots fired, and confirming that Cruz was absent from the immediate area during the attack.
Ismael Doro Rivera provided additional context by noting that he saw Rolando Cruz talking with Rading Sason prior to hearing the shots, suggesting some level of interaction between the two.

The prosecution relied heavily on Rivera’s testimony regarding a conversation between Cruz and Sason, where Cruz allegedly uttered “andiyan na.”

The phrase was interpreted by the trial court as an indication of a conspiracy between the accused and the triggerman.

Evidence of premeditation included the backdrop of a personal grudge stemming from an earlier incident related to a church wedding involving the victim and family members.

Rolando Cruz pleaded not guilty, claiming that he was engaged in activities near his mother’s house and only responded upon learning about the shooting.
The trial court, after hearing the testimonies of six prosecution witnesses and reviewing the medico-legal evidence, found Cruz guilty beyond reasonable doubt as a co-principal in murder by inducement.
The decision also ordered Cruz to indemnify the heirs of the offended party to the tune of P30,000.00, alongside a sentence of reclusion perpetua.

The defense argued that the term “andiyan na” is ambiguous, commonly used in ordinary conversation without conspiratorial intent.
The same eyewitness, Rivera, seemingly contradicted the inherent conspiracy element by later affirming that there was no clear evidence of a prearranged plan to kill Baang.
The defense emphasized that any inference of conspiracy must be supported by clear and convincing evidence, which was allegedly lacking in this case.

Whether the trial court erred in interpreting the phrase “andiyan na” as indicative of a conspiracy between Rolando Cruz and Rading Sason.

Did the utterance have a conspiratorial connotation or was it merely a common expression?
Could the ambiguous nature of the phrase have led to an erroneous inference of intent?

Whether the evidence was sufficient to establish beyond reasonable doubt that Rolando Cruz was a principal by inducement in the commission of murder.

Is mere presence or indirect association enough to prove active participation in the crime?
Does the lack of eyewitness identification of Cruz during the shooting undermine the prosecution’s case?

Whether the evidence presented was strong enough to impute criminal complicity to Cruz, either as a principal or an accomplice.

Can the interaction between Cruz and Sason prior to the shooting be conclusively linked to a criminal plan?
Does the circumstantial nature of the evidence permit a finding of guilt, or should reasonable doubt prevail?

The propriety of basing a conviction on potential conjectures regarding personal grudges and alleged threats made by Cruz.

Were the emotional motivations and alleged threats sufficiently established to infer a criminal purpose?
How does the emotional context affect the legal standard required for a murder conviction?