People v. Linsangan
REITERATIONFacts
The Antecedents: Appellants Eduardo Linsangan and Mario Castro, Jr., along with Renato Linsangan, Jr. and Gerardo Cayanga, were charged with the murder of Fernando de Guzman. The prosecution alleged that on November 15, 1987, in Barangay Santor, Bongabon, Nueva Ecija, the accused conspired to attack and kill the victim. Renato Linsangan, Jr. allegedly wielded a bolo, Eduardo Linsangan restrained the victim, and Mario Castro, Jr. and Gerardo Cayanga used stones. The victim sustained multiple serious injuries, resulting in his death. Renato Linsangan, Jr. remains at large, and Gerardo Cayanga was discharged to become a state witness. Procedural History: Appellants Eduardo Linsangan and Mario Castro, Jr. were arrested and arraigned separately, entering pleas of not guilty. Eduardo Linsangan was granted a separate trial. After separate proceedings, the Regional Trial Court in Palayan City, Branch 40, rendered a decision on August 30, 1990, finding both Eduardo Linsangan and Mario Castro, Jr. guilty of murder and sentencing them to reclusion perpetua. Both accused appealed this decision to the Supreme Court. The Petition: The accused-appellants, in their separate briefs, raised three main arguments before the Supreme Court. They contended that the trial court erred in not acquitting them due to insufficient evidence, in finding that a conspiracy existed among the accused, and in disregarding the testimonies of the defense witnesses and an affidavit of desistance executed by the victim's wife. The Supreme Court reviewed these arguments, focusing on the existence of conspiracy, and ultimately affirmed the trial court's judgment in its entirety.
Issue(s)
Whether the evidence presented was sufficient to convict the accused-appellants of murder, and whether conspiracy was sufficiently established among the accused. Whether the affidavit of desistance executed by the victim's wife should have been considered in favor of the accused-appellants.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused-appellants Eduardo Linsangan and Mario Castro, Jr. guilty of murder beyond reasonable doubt and sentencing them to suffer the penalty of reclusion perpetua. The Court found that conspiracy was sufficiently established and that the act of one conspirator was the act of all. The affidavit of desistance was correctly disregarded by the trial court.
Ratio Decidendi
On the sufficiency of evidence and conspiracy: The Court held that a conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. While no express prior agreement was proven, the existence of conspiracy can be inferred from the concerted acts of the accused. The evidence showed that Renato Linsangan and his three companions, including Eduardo Linsangan and Mario Castro, Jr., together fetched the victim, Fernando de Guzman. They held him by the shoulder, preventing his escape. The widow testified that she saw Eduardo Linsangan hitting her husband with a stone after he was hacked by Renato Linsangan. This was corroborated by the medico-legal report indicating contused wounds on the victim's head, consistent with being hit by blunt objects like stones. Daniel Fernando also identified the same individuals as holding the victim by the shoulder. The Court reiterated that conspiracy may be inferred from the acts of the accused themselves when such acts point to a joint purpose and design, and that their actions are the best index of their intention. Therefore, the act of one conspirator in furtherance of the common design is the act of all, and each conspirator is guilty in equal degree. On the affidavit of desistance: The Court affirmed the trial court's decision to disregard the affidavit of desistance executed by the victim's wife after she had already testified. The Court reasoned that such an affidavit, executed after the witness had voluntarily testified and implicated the accused, is unreliable. The witness cannot preempt the court's determination of the sufficiency of the evidence. At most, an affidavit of desistance constitutes a waiver of the civil liability of the accused, which the trial court correctly did not award.
Main Doctrine
Conspiracy to commit murder may be inferred from the concerted acts of the accused, even without proof of a prior agreement. The act of one conspirator in furtherance of the common design is the act of all. An affidavit of desistance executed by a witness after testifying does not automatically warrant acquittal.