PEOPLE v. CIELITO BULURAN Y RAMIREZ

FACTS:

On May 16, 1993, the Meyer family was celebrating the birthday of their mother at their residence in Barangay Amaparo, Quezon City. Dominador Meyer, Jr. had an altercation with a cousin and Edilberto Meyer, Sr. tried to pacify them. While outside the house, Reynaldo Danao approached and warned them not to cause any trouble. The victim denied making trouble and said it was a family problem. Reynaldo punched the victim, and they engaged in a fight. Reynaldo ran away but returned with his friends Cielito Buluran, Leonardo Valenzuela, and Jaime Danao. Reynaldo stabbed the victim while Cielito, Leonardo, and Jaime pointed their weapons at the Meyer brothers and prevented others from interfering. The four fled, and the victim died that same night. Appellants Cielito Buluran and Leonardo Valenzuela were arrested and tried for murder. During trial, the prosecution presented three eyewitnesses, a police officer who invited appellant Buluran to the precinct, and the medico-legal officer who conducted the autopsy. The defense denied involvement and presented alibi witnesses. The trial court found appellants guilty of murder and sentenced them to reclusion perpetua, indemnity, and damages.

ISSUES:

  1. Whether or not the appellants are guilty of the crime of murder.

  2. Whether or not there is conspiracy among the appellants.

RULING:

  1. The court found the appellants guilty beyond reasonable doubt of the crime of murder. They were both sentenced to suffer the penalty of reclusion perpetua. They were also ordered to jointly and severally indemnify the heirs of the deceased in the amount of P8,000 as actual damages and P50,000 as death indemnity.

  2. The court found that there was conspiracy among the appellants. They acted in concert, with one of them stabbing the victim while the others pointed and brandished their weapons to prevent anyone from interfering. This showed a common design and unity of purpose, establishing the existence of conspiracy.

PRINCIPLES:

  • Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. It may be inferred from the conduct, relationship, acts, and circumstances of the accused before, during, and after the commission of the crime.

  • To establish conspiracy, it is not necessary to prove the actual agreement between the accused. It is enough that they acted in concert, demonstrating a unity of purpose and intention to achieve the same criminal objective. Each conspirator is responsible for the acts of his co-conspirators done in pursuit of their common plan.