People v. Veronas
REITERATIONFacts
The Antecedents: On November 20, 1980, at approximately 7:30 PM, Marciana Legaspi, a 65-year-old widow, and her sister Demetria Mancao were inside their house in Barili, Cebu. Three men, later identified as Sabino Veronas, Rodrigo Cañete, and Nelson Abala, entered the premises. Demetria was attacked and subdued by Veronas, while Marciana was threatened with a knife by Cañete and Abala. The assailants robbed Marciana of various valuables worth P3,320. Subsequently, Nelson Abala and Rodrigo Cañete raped Marciana Legaspi against her will. After the robbery and rape, Abala searched the house for more valuables, prompted by a statement attributed to "Annie" (Anacleto Asister) that Marciana was wealthy. The accused then left. Demetria managed to free herself and untie Marciana. They saw Anacleto Asister sitting nearby, who did not intervene. The sisters proceeded to the Poblacion to report the crime and seek medical attention. The perpetrators were apprehended by a PC detachment and positively identified by the victims. Procedural History: An information was filed charging Anacleto Asister and his three companions with robbery with rape and double less serious physical injuries. All pleaded not guilty. The trial court, finding the accused guilty beyond reasonable doubt as co-conspirators, convicted them and sentenced them to suffer reclusion perpetua, to indemnify the victim, and to pay costs. Anacleto Asister and Nelson Abala appealed. Abala later withdrew his appeal. The Petition: The lone appellant, Anacleto Asister, argued that the trial court erred in finding him guilty as a co-conspirator and in denying his motion for a new trial.
Issue(s)
Whether the trial court erred in finding the appellant guilty as a co-conspirator in the commission of the crime of robbery with rape. Whether the trial court erred in denying the appellant's motion for a new trial.
Ruling
The Supreme Court affirmed the decision of the trial court in toto, holding that the appellant Anacleto Asister was guilty as a co-conspirator in the crime of robbery with rape. The Court also affirmed the denial of the motion for a new trial.
Ratio Decidendi
On the issue of conspiracy: The Court held that the findings of the trial court were supported by the evidence on record and in accordance with law. The appellant's defense of alibi was found to be inherently weak and unsubstantiated by clear and convincing evidence. This defense could not prevail over the positive identification made by the prosecution witnesses who saw him at the scene of the crime. Furthermore, the interlocking confessions of his co-accused implicated him as the mastermind of the robbery, stating that he guided them to Marciana's house and watched the events unfold without attempting to prevent the commission of the crime by his companions. The Court reiterated the well-settled rule that in a conspiracy, the act of one is the act of all, and each conspirator is liable for all the crimes committed by the other conspirators. Therefore, even if only Abala and Cañete committed the rape, their companions, including Asister, who lifted not a finger to prevent it, are equally guilty. The Court cited People vs. James Arbis, People vs. Atencio, and People vs. Reyes in support of this principle. On the denial of the motion for a new trial: The Court found that the trial court correctly denied the motion for a new trial. The motion was based on the ground that other accused retracted their testimonies in court. However, these retractions were made after the trial court had already rendered its decision convicting the accused. The Court emphasized that the retraction of previous testimony is not a ground for a new trial, citing People vs. Navasca. Therefore, the denial of the motion was proper.
Main Doctrine
In conspiracy, the act of one is the act of all, and each conspirator is liable for all crimes committed by the other conspirators, even if they did not directly participate in the commission of a specific crime like rape, provided they did not attempt to prevent it.