People v. Tan
REITERATIONFacts
The Antecedents: On March 18, 1986, at approximately 11:30 in the evening, Rodulfo Hinuctan and his companions were on their way home after drinking. Their path was blocked by the accused Vicente Tan, Eddie Tan, Federico Fajardo, and Meliton Valencia, who were armed with bladed weapons (except for Valencia). Federico Fajardo approached Hinuctan with a bolo, while Vicente Tan stabbed Hinuctan with a kitchen knife on the right side of his body below the armpit. Hinuctan fell and, as he lay bleeding, Eddie Tan remarked that he was dead. Hinuctan was rushed to the hospital but died shortly thereafter due to a fatal stab wound that penetrated his lungs, causing internal hemorrhage. Procedural History: An information for homicide was filed against the accused, which was later amended to murder, alleging conspiracy, treachery, and evident premeditation. The Regional Trial Court dismissed the case against Meliton Valencia but found Vicente Tan, Eddie Tan, and Federico Fajardo guilty of murder, qualified by evident premeditation, holding that treachery was not present. The accused appealed. The Petition: The accused-appellants raised errors concerning the finding of conspiracy among them and the presence of evident premeditation in the killing of the deceased.
Issue(s)
Whether there was conspiracy among the three accused in the stabbing of the deceased Rodulfo Hinuctan. Whether the killing of the deceased by Eddie Tan was attended with evident premeditation.
Ruling
The appealed judgment finding appellants Vicente Tan, Eddie Tan, and Federico Fajardo guilty of murder is AFFIRMED. The penalty of reclusion perpetua and the civil indemnity are maintained.
Ratio Decidendi
On the issue of conspiracy: The Court affirmed the existence of conspiracy among the appellants. The facts showed that the appellants blocked the path of Hinuctan and his friends, were armed with deadly weapons, and coordinated their movements in assaulting Hinuctan. While Fajardo engaged Hinuctan, Vicente Tan delivered the fatal stab wound, and Eddie Tan confirmed the victim's death. The appellants then fled together. This coordinated action demonstrated a community of design and a synchronized effort towards the objective of liquidating Hinuctan as a measure of vengeance. Therefore, as co-conspirators, their criminal responsibility is equal and collective. On the issue of evident premeditation: The Court found that evident premeditation qualified the killing to murder. Eddie Tan testified that he was mauled by Hinuctan at around 10:00 p.m., after which he secured a medical certificate and then went home to retrieve a knife to retaliate. He caught up with Hinuctan around 11:00 p.m. and stabbed him at approximately 11:30 p.m. This one-hour and thirty-minute interval between the initial thought of revenge and the actual stabbing provided sufficient time for reflection and cool thought. Eddie Tan had the opportunity to recover his equanimity and desist but instead chose to pursue Hinuctan, retrieve a weapon, and enlist the help of others. This chain of events, culminating in the stabbing, indicated that the appellants were actuated by a spirit of lawlessness and revenge rather than a sudden impulse of uncontrollable fury, satisfying the requirement of deliberate premeditation as defined in People vs. Durante and applied in People vs. Cabrera and People vs. Dumdum.
Main Doctrine
Conspiracy among the accused in the commission of murder, coupled with the aggravating circumstance of evident premeditation, warrants conviction for murder and imposition of reclusion perpetua. The collective criminal responsibility of co-conspirators is equal, regardless of who inflicted the fatal wound.