Case Summary (G.R. No. 188832)
Applicable Law
The case involves the interpretation of provisions under the Revised Penal Code of the Philippines, particularly Article 16, regarding criminal liability as a principal or an accessory. The legal framework applicable to this case is derived from the Revised Penal Code, which was in effect prior to the 1987 Constitution.
Procedural History
Vino was charged with murder after the shooting of Roberto Tejada. The trial court found him guilty as an accessory to murder, imposing a penalty and ordering him to indemnify the victim’s heirs. A motion for reconsideration was denied, leading to an appeal to the Court of Appeals, which affirmed the trial court's decision. The case was notable for Salazar’s subsequent acquittal in a separate trial.
Primary Legal Issues
The central issue is whether Vino's conviction as an accessory to murder can stand following the acquittal of the alleged principal, Jessie Salazar. The petitioner raised several arguments, including the sufficiency of evidence and the procedural propriety in convicting an accessory while the principal stands acquitted.
Ruling on Accessory Convictions
The court ruled that a defendant charged as a principal can be convicted as an accessory based on the evidence presented, as long as the act committed and the level of participation are established. In this case, the evidence indicated that Vino knowingly assisted in the movement of Salazar after the crime, thereby fulfilling the role of an accessory despite being charged as a principal.
Distinction Between Principal and Accessory Charges
The court affirmed that the liability of the principal and the accessory can be treated separately. Thus, even if the principal is acquitted, the accessory can still be held liable provided the accessory's actions were proven beyond a reasonable doubt. The necessary condition is the establishment of the crime's commission and the accessory's involvement.
Impact of Principal’s Acquittal on Accessory Liability
The key question of whether Vino's conviction could be maintained after Salazar’s acquittal was resolved by determining the nature of the evidence. While the acquittal of Salazar suggested doubt regarding his identity as the shooter, the prosecution still established that Vino actively aided Salazar's escape, hence maintaining his liability as an accessory.
Conclusion on the Motion for Reconsideration
The court ultimately denied the motion for reconsideration filed by Vino, asserting that his conviction as an access
...continue readingCase Syllabus (G.R. No. 188832)
Case Background
- The case concerns Lito Vino, who was charged and convicted as an accessory to the crime of murder in the Regional Trial Court of Rosales, Pangasinan.
- The incident in question occurred on March 21, 1985, when Roberto Tejada was shot, leading to his death.
- Witnesses reported seeing Lito Vino and Jessie Salazar, the alleged principal, fleeing the scene on a bicycle shortly after the shooting.
- Roberto Tejada identified Jessie Salazar as his assailant in an ante-mortem statement before dying.
Procedural History
- Lito Vino was charged with murder after the case against Jessie Salazar was transferred to the Judge Advocate General's Office due to his military status.
- Vino pleaded not guilty during his arraignment, and the trial commenced with the prosecution presenting evidence.
- Rather than defending himself, Vino filed a motion to dismiss for insufficiency of evidence, which was denied.
- The trial court found Vino guilty as an accessory to murder, sentencing him to an indeterminate prison term and ordering him to indemnify the victim's heirs.
Appeal and Acquittal of Principal
- Vino appealed the decision to the Court of Appeals, which affirmed the trial court's ruling.
- During the pendency of Vino's appeal, Jessie Salazar was acquitted of murder due to insufficient evidence to identify him as the shooter.
- This acquittal prompted Vino to file a motion for reconsideration, questioning the validity of his conviction