Facts:

• The accused-appellant, Rodolfo Federico y Mediona, was charged with murder for the killing of Pastor Neil Escala y de Guzman.
• The incident happened on March 17, 1990, in Manila, Philippines.
• The accused-appellant was accused of conspiring and confederating with others to attack and stab Escala multiple times, causing his death.
• The trial court found the accused-appellant guilty beyond reasonable doubt and sentenced him to reclusion perpetua.
• The accused-appellant appealed the decision, claiming that he did not conspire or cooperate with the assailant in stabbing the victim.

Issue:

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Ruling:

• The Supreme Court affirmed the decision of the trial court but modified the extent of the accused-appellant's criminal liability and the imposable penalty.
• The accused-appellant was found guilty beyond reasonable doubt of the crime of murder but only as an accomplice.
• His penalty was reduced from reclusion perpetua to an indetermina...(Unlock)

Ratio:

• Conspiracy must be established by proof beyond reasonable doubt.
• Co-conspirators are only liable for acts done pursuant to the conspiracy.
• The accused-appellant cannot be held liable as a co-conspirator for the killing of Escala because there was no evidence of his involvement or awareness of the assailant's intent to attack Escala.
• In the absence of a conspiracy, the criminal responsibility for acts directed against one person is individual and not collective.
• The accused-appellant is liable as an accomplice under Article 18 of the Revised Penal Code because he cooperated in the execution of the ass...continue reading