FACTS:
The accused, Rolando Maranion, and his co-accused, Arsenio Ragudo, were found guilty of Robbery with Double Homicide by the Regional Trial Court (RTC). They appealed the decision. Two separate informations were filed against the accused, one for Robbery by a Band with Double Homicide and another for Illegal Possession of firearms. Both Maranion and Ragudo pleaded not guilty to both charges. The trial court conducted a joint hearing for the two cases and proceeded with the trial only for Maranion and Ragudo. Witnesses, including Margarita See Chi, testified for the prosecution. Margarita, the widow of the victim, stated that Maranion and his companion, Patrolman Antonio Benito, arrived at their store on the night of the incident and announced a hold-up. The victims were forced inside a room, gunshots were heard, and Margarita discovered her husband and another victim dead with the cash missing. Other witnesses also testified to Maranion's presence and involvement in the robbery.
On the day of the robbery, Margarita Figueroa, a saleslady at the store, witnessed two men fleeing the scene towards a taxi parked at a nearby gasoline station. One of the men was armed with a gun, while the other was identified as Rolando Maranion carrying an unidentified object. Margarita noted that the taxi drove towards the men, who boarded the vehicle and quickly left.
Sgt. Antonio Sityar of the Pasig Police took Rolando Maranion's extrajudicial confession, during which Maranion identified his co-accused, Pat. Antonio Benito, from a file of police photographs.
Ester de la Cruz, the widow of a victim, testified that her deceased husband used to earn about P1,500 per month from typing jobs. She also mentioned spending P15,000 for burial expenses.
Dr. Bienvenido Munoz, the Medico-Legal Officer of the NBI, conducted the post-mortem examination on William See Chi's body. The deceased victim died from gunshot wounds inflicted by two guns of similar caliber.
Defense witness Arsenio Ragudo, the taxi driver, supported Maranion's testimony. He stated that they waited for Pat. Benito and had a snack together in Antipolo. Ragudo also confirmed that Pat. Benito later boarded the taxi after the robbery, instructed Maranion to comply with his orders, and prevented Maranion from seeking medical attention at a hospital due to fear of investigation.
ISSUES:
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Whether there is sufficient evidence to prove the existence of a conspiracy between the accused-appellant and his co-accused.
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Whether the appellant's participation in the crime has been proven beyond reasonable doubt.
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Whether there was evidence to establish conspiracy between the appellant and the co-accused.
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Whether the appellant's conduct before, during, and after the commission of the crime showed his guilt in the offense charged.
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Whether the crime committed in the case is Robbery with Homicide.
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Whether the appellant can be held liable as a principal in the special complex crime of robbery with homicide.
RULING:
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The court found that there is sufficient evidence to prove the existence of a conspiracy between the accused-appellant and his co-accused. The evidence on record shows that the accused-appellant and his co-accused were together before, during, and after the commission of the crime. They were seen together at the scene of the crime, and they fled together afterwards. Their actions and coordination during the commission of the crime establish their common purpose and intention to commit the robbery.
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The court held that the appellant's participation in the crime has been proven beyond reasonable doubt. Although the appellant claimed that he was tricked into joining his co-accused and that he had no knowledge of the plan to commit the robbery, the evidence disproves his claims. There were witnesses who testified that the appellant was present at the scene of the crime and actively participated in the commission of the robbery. The appellant's participation was not limited to mere presence, but also included acts such as pointing a gun, instructing the taxi driver to follow instructions, and preventing the appellant from seeking medical treatment for his gunshot wound.
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Yes, there was sufficient evidence to establish conspiracy between the appellant and the co-accused. The acts and behavior of the appellant before, during, and after the commission of the crime indicated a common understanding and agreement to commit the offense. Conspiracy need not be proven by direct evidence, but may be inferred from acts, conditions, and circumstances which indicate a common purpose and objective. In this case, the appellant's conduct, including closing the store door during the robbery and his actions and movements in coordination with the co-accused, showed a joint plan and design to commit the crime.
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The appellant's conduct before, during, and after the commission of the crime supported his guilt in the offense charged. His actions, such as closing the store door and being present at the store counter during the robbery, indicated his active participation and knowledge of the criminal act. Additionally, his failure to report the incident to the authorities for thirteen days and his attempt to flee the scene with the co-accused further demonstrated his complicity in the offense. The principle that when there is conspiracy, the act of one is the act of all applies, making all conspirators equally responsible for the acts done in furtherance of the conspiracy.
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The crime committed in the case is Robbery with Homicide. The killings of the victims are directly linked to the robbery and occurred during and on the occasion of the robbery. The degree of actual participation in the commission of the crime is immaterial in a conspiracy. The result obtained, without reference to the circumstances, causes, modes, or persons intervening in the commission of the crime, is the only thing to be considered.
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All those who took part in the commission of the robbery as principals are also considered principals in the special complex crime of robbery with homicide, even if they did not actually participate in the homicides. However, if it clearly appears that any or some of them endeavored to prevent the homicide, they may not be adjudged as principals. In the case at hand, there is no evidence showing that the appellant tried to prevent the killing of the victims. Therefore, the appellant can be held liable as a principal in the special complex crime of robbery with homicide.
PRINCIPLES:
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Conspiracy can be established through proven facts and circumstances that show the coordination and common purpose of the accused in committing the crime.
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Mere presence at the scene of the crime is not enough to establish guilt beyond reasonable doubt, but active participation and involvement in the commission of the crime can establish guilt even without direct evidence of prior agreement or planning.
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Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.
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Conspiracy need not be established by direct evidence, but may be proven by a number of indefinite acts, conditions, and circumstances indicating a common design to accomplish a criminal purpose.
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The existence of conspiracy is a matter of inference deduced from certain acts done in pursuance of a common unlawful purpose.
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In a conspiracy, the act of one is the act of all, and all persons taking part in the crime shall be held guilty as principals.
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The act of a conspirator is considered the act of all co-conspirators.
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The degree of actual participation in the commission of a crime is immaterial in a conspiracy.
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Where the killing of the victims is directly linked to the robbery and occurred during and on the occasion of the robbery, the crime committed is robbery with homicide.
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The nature of the crime of robbery with homicide is that the homicides, irrespective of their number, committed on the occasion of or by reason of the robbery, are merged in the composite crime of robbery with homicide.
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The number of persons killed is immaterial and does not increase the penalty prescribed for robbery with homicide.