People v. Peralta
REITERATIONFacts
The Antecedents: On February 16, 1958, within the New Bilibid Prisons, six inmates (Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita, and Florencio Luna) were charged with the murder of three other inmates: Jose Carriego, Eugenio Barbosa, and Santos Cruz. The information alleged that the accused, all convicts serving sentences, conspired, confederated, and aided one another with evident premeditation and treachery, using deadly weapons, to kill the victims by inflicting multiple serious injuries. The aggravating circumstance of quasi-recidivism was also alleged, as the crime was committed while the accused were serving final judgments. Additional aggravating circumstances included insult to public authorities, commission by a band, use of armed men for impunity, superior strength, breaking of doors and windows, adding ignominy, and commission where public authorities were engaged in their duties. Procedural History: The Court of First Instance of Rizal found Amadeo Peralta, Andres Factora, Leonardo Dosal, Angel Parumog, Gervasio Larita, and Florencio Luna guilty of multiple murder and sentenced them to death. They were also ordered to indemnify the heirs of each victim. The case was subject to automatic review by the Supreme Court. The Petition: The defendants appealed their conviction and sentence.
Issue(s)
Whether conspiracy attended the commission of the murders. Whether evident premeditation was present. Whether the aggravating circumstance of quasi-recidivism was correctly appreciated. Whether the accused are guilty of three separate and distinct crimes of murder. Whether multiple death penalties should be imposed upon each of the accused.
Ruling
The Supreme Court modified the judgment of the trial court. It found that conspiracy attended the commission of the murders. It ruled that evident premeditation was not present. It affirmed the presence of quasi-recidivism. The Court held that the accused were guilty of three separate and distinct crimes of murder and sentenced each of them to three death penalties. They were ordered to jointly and severally indemnify the heirs of each victim in the sum of P12,000.00 and to pay one-sixth of the costs.
Ratio Decidendi
On the presence of conspiracy: The Court held that conspiracy attended the commission of the murders. While there was no direct evidence, several circumstances indicated a planned crime. These included the victims being Tagalogs and members of the rival "Sigue-Sigue" gang, while the accused were "OXO" members or sympathizers from Brigade 4-A. The accused were all armed with improvised weapons, demonstrating preparation. Their actions showed "team work precision" as they moved from one brigade to another, attacking marked individuals. Almost the same people participated in the killing of all three victims. The Court emphasized that once conspiracy is proved, all conspirators are liable as co-principals, and the act of one is the act of all, even if they did not participate in every act of execution. On evident premeditation: The Court disagreed with the trial court that evident premeditation was present. It clarified that evident premeditation is not inherent in conspiracy. Unlike evident premeditation, which requires a sufficient period for meditation and reflection, conspiracy arises at the moment the plotters agree to commit a felony and decide to do so. The Court found no proof of how or when the plan was hatched or the time elapsed between its inception and fulfillment, thus precluding a finding of evident premeditation. On quasi-recidivism: The Court affirmed the presence of the special aggravating circumstance of quasi-recidivism. It noted that all six accused were inmates serving sentences in the New Bilibid Prison by virtue of final judgments at the time of the commission of the offenses. This circumstance mandates that the penalty for each offense must be imposed in its maximum period, as per Article 160 of the Revised Penal Code. On guilt for three separate murders: The Court ruled that each of the six accused was guilty of three separate and distinct crimes of murder. It reiterated the doctrine that in conspiracy, the act of one is the act of all, and each conspirator is liable for all crimes committed in furtherance of the common design. Therefore, each accused was liable for the murder of Carriego, Barbosa, and Santos Cruz. On the imposition of multiple death penalties: The Court held that multiple death penalties should be imposed upon each of the accused. Citing jurisprudence, the Court stated that once conspiracy is established, each conspirator is liable for each of the felonious acts committed as a result of the conspiracy, regardless of the nature and severity of the penalties. The Court reasoned that the imposition of multiple death penalties is legally permissible and practically important, serving as an indelible badge of extreme criminal perversity and potentially deterring improvident grants of clemency. The Court modified the trial court's sentence to impose three death penalties on each accused.
Main Doctrine
Once conspiracy is proven, all conspirators are liable as co-principals for all crimes committed in furtherance of the conspiracy, regardless of their individual participation. The act of one is the act of all. Each conspirator is liable for each distinct crime committed, and multiple penalties may be imposed accordingly.