G.R. No. 225565 - Camp John Hay Development Corp. vs. Office of the Ombudsman

On or about July 24, 1991, a group of individuals—including appellant Reyderick Lago, co-accused Cozette Aragon, Jayson Diadid, Rainier Lisbog, and an absent member Dennis Sison—conspired to commit a robbery that culminated in homicide.
The plan involved entering the house of Benjamin Raymundo y Sta. Teresa in Mandaluyong by forcibly opening a window using a 29-inch “balisong” knife.
Once inside, the group proceeded to appropriate cash, jewelry, and other valuables, and during the process, the victim was stabbed repeatedly (21 wounds in total), which directly led to his death.

Witnesses such as Rosana Capacillo and Ramon Bernardo testified regarding the movements and identities of the accused on the day of the crime.
Dr. Alberto Reyes, the medico-legal officer, detailed the extent and fatal nature of the victim’s injuries, emphasizing the 21 stab wounds that affected vital organs like the lung, liver, and pancreas.

Appellant Reyderick Lago claimed he was merely an incidental participant, asserting his role was limited to accompanying Cozette Aragon under the pretext of school-related errands (collecting a project and salary).
He contended that he neither intended nor participated in the killing and that his departure from the scene upon hearing a groan was indicative of his non-involvement in the homicide.

The Information dated August 14, 1991, formally charged appellant and his co-accused with a robbery that escalated into homicide.
Evidence presented at trial—including forensic reports from the autopsy, eyewitness testimonies, and the conduct of the accused—substantiated that the robbery and subsequent homicide were interlinked.
The Regional Trial Court (RTC) in Pasig found that the aggregate evidence met the requirement of proof beyond a reasonable doubt. They determined that the acts of the co-conspirators, including the repeated stabbing, were duly connected to the common plan, thereby implicating all participants.

At the scene, after the murder commenced, appellant was positioned on the sofa waiting while his co-accused executed the homicide.
Upon hearing a groaning sound from the victim’s bedroom, appellant became apprehensive and chose to leave without intervening or alerting authorities.
Post-crime, appellant evaded immediate apprehension by hiding for two years—first at his grandmother’s residence, then at his mother’s—until his eventual arrest in January 1994.

Whether the evidence presented, including witness testimonies and forensic findings, sufficiently established beyond a reasonable doubt the appellant’s participation in a conspiracy to commit robbery with homicide.
Whether the direct and circumstantial evidence, despite showing that appellant did not physically stab the victim, conclusively linked him to the overarching criminal act.

Whether the principle that “the act of one is the act of all” applies in this case, thereby holding appellant equally liable for the homicide committed by his co-conspirators.
Whether appellant’s claim of limited involvement (being present solely to assist with the robbery) is adequate to exclude him from liability for the homicide.

Whether the elements of the special complex crime of robbery with homicide—namely, the commission of robbery accompanied by homicidal acts—are satisfied in the case at hand.
Whether all participants in the robbery, by virtue of their conspiracy, are automatically criminally liable for the resultant homicide, notwithstanding a lack of direct participation in the killing.