In People vs. Joey and Mario Manlansing, the Supreme Court clarified the complexities of proving conspiracy in homicide cases. While one brother confessed to the killings, the Court examined the evidence to determine the other’s involvement. This case highlights how the actions and statements of individuals before, during, and after a crime can establish a shared intent, leading to shared criminal responsibility, even if one person didn’t directly commit all acts.

Brothers in Blood: Did Both Conspire in the Soriano Double Homicide?

Joey and Mario Manlansing were initially sentenced to death for the murder of spouses Magin and Jorja Soriano, their landlords. The case reached the Supreme Court on automatic review, focusing on whether Joey conspired with Mario in committing the crimes. Mario confessed to the killings, claiming his brother was not involved. However, the prosecution presented circumstantial evidence suggesting a conspiracy, leading to a deeper examination of the legal principles surrounding conspiracy and its implications for criminal liability.

The Supreme Court scrutinized the trial court’s decision, which convicted both appellants based on Mario’s confession and the presented circumstantial evidence. The critical issue was whether the evidence sufficiently proved a conspiracy between the brothers. The Court noted that conspiracy requires an agreement between two or more persons to commit a crime and a decision to execute it. This agreement doesn’t need to be formal; a shared intent manifested through their actions at the time of the crime is sufficient. In assessing conspiracy, courts often look at the accused’s conduct before, during, and after the crime.

In this case, several pieces of evidence pointed towards Joey’s involvement. The medical officer’s testimony revealed that the victims suffered wounds inflicted by different weapons, suggesting more than one attacker. Also, two weapons were recovered—a bolo, admitted to be Mario’s and a knife discovered beneath one of the victims. Further, the fingerprint expert confirmed that Joey’s fingerprints matched some found at the crime scene, while the balut vendor testified to seeing two men with bloodied shirts leaving the crime scene. Additionally, the testimony from Joey himself became crucial, as he admitted to hitting Jorja “para walang marinig” (“so no one would hear”), but altered his version during trial. It’s the Court’s position that “Testimonies to be believed must not only come from the mouth of credible witnesses but should by themselves be credible, reasonable and in accord with human experience.”

The Supreme Court weighed the claim that only Mario single-handedly killed the spouses. While Mario confessed, inconsistencies and contradictions arose, especially as the injuries sustained by both victims seemed to require different weapons and more than one assailant. Adding weight, footprints and fingerprints of both brothers were identified from the crime scene. Both men were observed to have wiped away handprints and searched the premises for valuables after the murders were committed. It became apparent that the brothers were engaged in coordinated actions.

Ultimately, the Supreme Court agreed with the trial court’s conclusion that Joey conspired with Mario, holding him equally responsible for the deaths of the Sorianos. However, based on an assessment of the information filed and applying newly adopted revisions of the Rules of Court, the Court ruled that the offenses could not be qualified as murder, lowering the judgement to double homicide. The Revised Rules on Criminal Procedure state that the information shall state the designation of the offense and the acts or omissions constituting it but shall also specify its qualifying and aggravating circumstances.

In the case, the aggravating circumstances of abuse of superior strength and dwelling were not alleged in the information. Also, the Court clarified that nocturnal considerations were not present here as darkness wasn’t sought by offenders. The Court affirmed Mario’s admission to planning for murder. Further the element of treachery was apparent as the Sorianos hosted them without knowing of their intent. Treachery ensures the execution of the crime without risk to the aggressor, without provocation from the victim.

Regarding mitigating circumstances, the Court determined that Mario’s surrender was not voluntary. However, the trial court failed to acknowledge his guilty plea. As such, the Court determined, “When both mitigating and aggravating circumstances attend the commission of the crime, the court shall reasonably allow them to offset one another in consideration of their number and importance, for the purpose of applying the penalty.” And regarding Joey, no mitigating circumstance existed.

Finally, the Court addressed the issue of damages, noting that the prosecution failed to provide supporting receipts. While entitled to temperate damages of ₱10,000 for each victim’s funeral expenses, they reduced the moral damages award. As a result, they ordered the accused to indemnify the family, with ₱50,000 in civil indemnity, ₱50,000 as moral damages, and ₱10,000 as temperate damages.

FAQs

What was the central issue in the case?	The key issue was whether Joey Manlansing conspired with his brother Mario in the killing of spouses Magin and Jorja Soriano, even though Mario confessed to acting alone. The court examined the circumstantial evidence to determine Joey’s level of involvement and criminal liability.
What is legal definition of conspiracy?	Conspiracy exists when two or more individuals agree to commit a crime and decide to pursue it. It does not require a formal agreement, as a shared intent manifested through actions during the crime is sufficient.
What kind of evidence can prove conspiracy?	Evidence of conspiracy can include actions taken before, during, and after the crime that show a common purpose. This may include witness testimonies, physical evidence linking individuals to the crime scene, and inconsistencies in their statements.
What is the effect of a guilty plea in sentencing?	A plea of guilty during arraignment can be considered a mitigating circumstance, potentially reducing the severity of the sentence. However, the court must still consider other aggravating circumstances present in the case.
How did the court rule on the damages awarded?	The court reduced the award for actual damages due to lack of supporting receipts. They reduced moral damages and awarded temperate damages instead and required indemnification.
Why was the initial conviction of murder lowered to homicide?	Based on an assessment of the information filed and applying newly adopted revisions of the Rules of Court, the Court ruled that the offenses could not be qualified as murder, lowering the judgement to double homicide. The Revised Rules on Criminal Procedure state that the information shall state the designation of the offense and the acts or omissions constituting it but shall also specify its qualifying and aggravating circumstances.
How is treachery legally defined?	Treachery means employing means directly and specially to ensure the execution of the crime without risk to the aggressor, arising from the defense which the offended party might make. This includes unexpected and sudden attacks depriving the victim of any chance to defend themselves.
What are the mitigating and aggravating circumstances?	A mitigating circumstance tends to reduce the severity of the sentence, and it could be Mario pleading guilty. On the other hand, aggravating circumstances tend to increase the severity of the sentence, such as evident premeditation and treachery for Joey.

The Manlansing case underscores the importance of carefully evaluating circumstantial evidence to determine the extent of an individual’s involvement in a crime. It also highlights the relevance of the newly revised rules on pleading. Ultimately, this ruling reinforces the principle that individuals who conspire to commit crimes will be held accountable, even if their direct participation is not immediately apparent.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People vs. Joey and Mario Manlansing, G.R. Nos. 131736-37, March 11, 2002