People v. Arhis
REITERATIONFacts
The Antecedents: Jesus Saturnino was summoned by appellant James Arhis. They discussed a planned robbery and Arhis drew a sketch of the victim Baldasan Tiongan's house. The next day, Arhis summoned Saturnino again and asked him to fetch appellant Henry Dizon. Arhis briefed Saturnino and Dizon on their mission to rob and, if necessary, kill Baldasan Tiongan, providing them with knives and fare money. They agreed to deposit a portion of the stolen money and divide the rest. Saturnino and Dizon proceeded to Baldasan Tiongan's house. They inquired about a certain Enrique Flores, then Saturnino asked for water. While Saturnino was in the kitchen, Dizon struck Baldasan with an empty coke bottle. As Baldasan went down the balcony steps to pick up stones, Saturnino stabbed him repeatedly until he heard voices responding to Baldasan's shouts for help. Saturnino and Dizon fled but were apprehended by rescuers. Procedural History: The Court of First Instance of Baguio and Benguet, Br. III, found appellants James Arhis and Henry Dizon guilty beyond reasonable doubt of Murder, qualified by treachery, evident premeditation, and abuse of superior strength. Co-accused Jesus Saturnino pleaded guilty and was sentenced accordingly. The trial court sentenced Arhis and Dizon to suffer reclusion perpetua, to indemnify the heirs of the deceased victim Baldasan Tiongan in the amount of P12,000.00, and to pay P21,000.00 for actual expenses during the wake. The Petition: Appellants James Arhis and Henry Dizon appealed the decision of the trial court.
Issue(s)
Whether a conspiracy existed to commit the offense charged. Whether Henry Dizon was correctly convicted as a co-conspirator and/or principal in the offense of murder. Whether the trial court erred in failing to consider facts and circumstances affecting the veracity and credibility of Jesus Saturnino's testimony.
Ruling
The appealed decision is hereby AFFIRMED, but the indemnity to the heirs of the deceased should be increased from P12,000.00 to P30,000.00.
Ratio Decidendi
On the existence of conspiracy: The Court found that a conspiracy among Arhis, Saturnino, and Dizon was easily discernible from their conduct before, during, and after the commission of the crime. Dizon's acceptance of a knife for self-defense, despite not knowing the full details of the "mission," reinforced the trial court's conclusion that he was in conspiracy and knew the purpose. The Court noted that Arhis provided the sketch of the victim's house, indicating prior planning and knowledge of the target. The appellants' admitted shortage of cash and Dizon's act of pledging his wristwatch for fare further supported the motive for robbery. Arhis' prior business transaction with the deceased, where the latter received a substantial amount, established that Arhis knew Baldasan had money stashed in his house. The fact that Saturnino and Dizon, strangers to the area, could readily pinpoint Baldasan's house was attributed to Arhis' sketch. Therefore, the evidence presented convincing proof that Saturnino, Dizon, and Arhis conspired to commit the crime. On the conviction of Henry Dizon: The Court affirmed the conviction of Henry Dizon as a principal in the offense of murder. Even if Dizon's extrajudicial confession admitting to hitting Baldasan with a bottle were disregarded, Saturnino's testimony corroborated this act. The Court held that all those who participate in a conspiracy are liable for the killing, unless there is proof that they tried to prevent it. Dizon's claim that he tried to prevent Saturnino from stabbing Baldasan was deemed self-serving and uncorroborated. The conspiracy was not limited to robbery; it extended to killing if necessary, as evidenced by Arhis' instructions and the provision of knives. Thus, Dizon was held liable for murder as a principal by direct participation. On the credibility of Jesus Saturnino's testimony: The Court found Jesus Saturnino's testimony credible and confirmed the material allegations of his extrajudicial confession, where he identified Arhis as the mastermind and Dizon as a direct participant. The Court reiterated that the fact that Saturnino was an ex-convict is not sufficient to destroy his credibility, especially when his testimony was corroborated by other evidence and the trial court found him credible. The trial court's assessment of credibility, based on the witness's demeanor and the evidence presented, is given great weight and will not be disturbed on appeal unless there is a clear showing of error. The Court found no such error in this case.
Main Doctrine
All participants in a conspiracy are liable for the killing, unless there is proof that they tried to prevent it. A conspiracy for robbery that results in murder makes all conspirators liable for murder.