People v. Marquez
REITERATIONFacts
The Antecedents: On the evening of December 23, 1965, inside an A.C. passenger jeepney in Davao City, victim Rolando Jardiel was stabbed from behind by one of the passengers, causing his death. An Amended Information charged Jacobito Marquez, Saturnino Jaron, and Celestino Abrigo with murder by conspiracy, alleging treachery and evident premeditation. Procedural History: All accused pleaded not guilty. Saturnino Jaron later pleaded guilty and was meted out an indeterminate penalty. The trial court found conspiracy among the accused and convicted Jacobito Marquez and Celestino Abrigo of murder, sentencing them to life imprisonment. Saturnino Jaron was excluded from this judgment as he had already been sentenced. Jacobito Marquez appealed the conviction, while Celestino Abrigo escaped and remained at large. The Petition: Appellant Jacobito Marquez appealed his conviction for murder, arguing that the prosecution failed to establish conspiracy between him and Saturnino Jaron, who admitted to being the one who stabbed the victim.
Issue(s)
Whether conspiracy was sufficiently established between appellant Jacobito Marquez and Saturnino Jaron. Whether appellant Jacobito Marquez is guilty of murder, considering the lack of established conspiracy and the evidence presented.
Ruling
The Supreme Court reversed and set aside the decision of the trial court with respect to appellant Jacobito Marquez, acquitting him on the ground of reasonable doubt. The Court found that the evidence presented by the prosecution was insufficient to establish conspiracy beyond reasonable doubt.
Ratio Decidendi
On the issue of conspiracy: The Court held that conspiracy must be established by positive evidence and cannot be founded on mere inferences and presumptions. It noted that Jaron admitted that the attack was sudden, unexpected, and done by him alone, without any preconceived plan. The Court emphasized that once conspiracy is established, the act of one conspirator is the act of all. However, in this case, the evidence did not establish a preconceived plan to commit the crime. The prosecution's evidence was deemed insufficient to prove conspiracy beyond reasonable doubt between Jaron and the appellant. On the issue of guilt of murder in the absence of conspiracy: The Court reiterated the principle that when the criminal act is not the result of a preconceived plan, the criminal liabilities of the participants can only be considered in the light of their individual participation, and not of a common criminal design. The victim received only one stab wound, inflicted by one person, and the appellant could only be held liable if a conspiracy between him and Jaron was proven. The Court cited People vs. Cutura to support the principle that individual liabilities must be determined in the absence of a common criminal design.
Main Doctrine
Conspiracy to commit a crime must be established by positive evidence and cannot be founded on mere inferences and presumptions. When the criminal act is not the result of a preconceived plan, the criminal liabilities of the participants can only be considered in light of their individual participation, not of a common criminal design.