People v. Caitor
REITERATIONFacts
The Antecedents: On March 10, 1983, at approximately 10:15 a.m., in Cebu City, Bashier Majid was attacked and killed. The information charged Reynaldo M. Caitor, Daniel R. Mercado, Federico L. Alazas, Victor Embuscado, Pepoy Embuscado, and Francisco Santosidad with murder. The prosecution presented evidence that the accused, acting in concert, assaulted Majid by boxing and shooting him, causing his death due to severe hemorrhage secondary to gunshot wounds. The necropsy report detailed multiple contusions, abrasions, a lacerated wound, and two gunshot wounds, one to the head and another to the chest, which were fatal. Procedural History: The Regional Trial Court of Cebu City convicted Reynaldo Caitor and Daniel R. Mercado of murder, sentencing them to reclusion perpetua and ordering them to indemnify the heirs of the victim. Federico Alazas and Francisco Santosidad were acquitted on grounds of reasonable doubt. Victor Embuscado and Pepoy Embuscado were at large. The Petition: Accused-appellants Reynaldo Caitor and Daniel R. Mercado appealed the decision, arguing that conspiracy did not exist between them and the Embuscado brothers, and that the latter were solely responsible for the killing. They also contended that the trial court erred in finding them guilty.
Issue(s)
Whether conspiracy exists between the accused-appellants and the Embuscado brothers. Whether the accused-appellants are guilty of murder.
Ruling
The Supreme Court affirmed the judgment of the trial court, finding the accused-appellants Reynaldo Caitor and Daniel R. Mercado guilty beyond reasonable doubt of the crime of murder. The indemnity was increased to THIRTY THOUSAND PESOS (P30,000.00).
Ratio Decidendi
On Whether conspiracy exists between the accused-appellants and the Embuscado brothers: The Court held that conspiracy was proven by the indefinite acts of the appellants, which were all aimed at accomplishing a common unlawful purpose. Witness Benjamin Fernandez testified that he saw Pepoy Embuscado, Reynaldo Caitor, and Daniel Mercado conversing, after which Pepoy Embuscado pointed to Bashier Majid and instructed Caitor and Mercado. Subsequently, Pepoy Embuscado, Daniel Mercado, Reynaldo Caitor, and Victor Embuscado went towards Majid. Mercado and Caitor pulled Majid, while Pepoy Embuscado searched the pushcart. They continued to drag Majid towards Gate No. 4, with Federico Alazas assisting. Upon entering the gate, Daniel Mercado ordered Francisco Santosidad to close it. Fernandez witnessed Majid being mauled by Caitor, Mercado, Alazas, and Victor Embuscado, while Pepoy Embuscado used a revolver to hit Majid's head and then shot him multiple times. Marlon Guangko and Felicidad Baybayanon corroborated the testimonies, describing how the accused dragged Majid and how Guangko was brushed aside when he intervened. The Court emphasized that conspiracy can be inferred from the concerted actions and unity of purpose demonstrated by the accused. The defense's claim of no conspiracy and their attempt to shift blame to the Embuscado brothers were undermined by the prosecution's evidence and the testimony of one of the accused, Francisco Santosidad, who denied fabricating the story about a blue bag. On Whether the accused-appellants are guilty of murder: The Court found that the evidence overwhelmingly established the guilt of the accused-appellants for murder. The testimonies of the prosecution witnesses, corroborated by the testimony of Francisco Santosidad, demonstrated a clear conspiracy and participation in the killing of Bashier Majid. The acts of dragging, mauling, and the subsequent shooting, all performed in concert, pointed to a common design to kill the victim. The necropsy report confirmed the fatal gunshot wounds and other injuries consistent with the assault described by witnesses. The Court rejected the defense's argument that the Embuscado brothers acted alone, noting that the appellants' actions, including their initial involvement in apprehending Majid and their subsequent presence during the assault, indicated their complicity. The Court also found that the introduction of the blue bag as evidence was a deliberate attempt to conceal the crime, further implicating the appellants. The flight of the Embuscado brothers and the appellants' subsequent actions were interpreted not as exculpatory but as part of a plan to escape criminal responsibility. Therefore, the appellants were held liable as principals by conspiracy for the crime of murder.
Main Doctrine
Conspiracy can be inferred and proven by the acts of the accused themselves when said acts point to a joint purpose and design, concerted action and community of interests, and such unity of purpose and concert of action serve to establish the existence of the conspiracy and the criminal liability as principals of the conspirators.