Proving Conspiracy: The Act of One is the Act of All in Robbery with Homicide

G.R. No. 108919, October 11, 1996

Imagine a seemingly simple errand turns into a nightmare because of the company you keep. This case underscores how easily one can become entangled in a web of criminal conspiracy, even without directly participating in the heinous act itself. The Supreme Court’s decision in People v. Cordero clarifies the legal principles surrounding conspiracy in robbery with homicide, emphasizing that the act of one conspirator is the act of all.

Understanding Conspiracy and its Implications

Conspiracy, in legal terms, is more than just being present when a crime occurs. It’s an agreement between two or more people to commit an illegal act. The Revised Penal Code, particularly Article 8, defines conspiracy as existing “when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.”

The key is the agreement and the decision to act on it. This means that even if you didn’t pull the trigger or directly steal the goods, if you were part of the plan, you’re just as liable. This principle is often summarized as “the act of one is the act of all.”

For example, imagine a group planning to rob a bank. One person drives the getaway car, another disables the alarm, and a third enters the bank to steal the money. Even if the driver never enters the bank, they are still guilty of robbery because they were part of the conspiracy.

The Facts of the Cordero Case: A Web of Criminal Intent

The case of People v. Cordero revolves around the robbery and killing of Gary Salvosa in Baguio City. Several individuals, including Edgar Cordero, Ernesto Pinlac, and Sales Sabadao, were implicated in the crime. The prosecution’s star witness, Marlon Angco, provided a detailed account of the events leading up to the robbery and homicide.

The story unfolds with Gary Salvosa, a businessman, visiting his commercial building. Security guard Edgar Cordero, along with a group including Ernesto Pinlac and others, conspired to rob Salvosa. The plan involved Cordero, who was on duty, allowing the group access to the building. Salvosa was then attacked, robbed of his valuables, and ultimately killed.

The case journeyed through the Regional Trial Court (RTC) of Baguio City, which found several of the accused guilty. The decision was then elevated to the Supreme Court, where the complexities of conspiracy were thoroughly examined.

• Accused Edgar Cordero and Domingo Batac pleaded guilty during arraignment.
• Marlon Angco was discharged and utilized as a state witness.
• The RTC found Cordero, Pinlac, Salazar, Domingo Batac, and Fred Batac guilty as principals.
• Sales Sabadao was held liable as an accomplice.

The Supreme Court emphasized the importance of establishing a common criminal intent among the accused. Here are some notable quotes from the decision:

“Conspiracy need not be proved by direct evidence of prior agreement to commit the crime. It may be inferred from the conduct of the accused before, during, and after the commission of the crime showing that they acted in unison with each other, evincing a common criminal purpose or design.”

“In conspiracy the act of one is the act of all.”

Practical Implications: What Does This Mean for You?

This case serves as a stark reminder of the far-reaching consequences of conspiracy. Even seemingly minor involvement in a criminal plan can lead to severe penalties. It highlights the importance of being mindful of the company you keep and the activities you associate with.

For businesses, this ruling underscores the need for thorough employee screening and strict adherence to legal and ethical standards. A company can be held liable for the actions of its employees if those actions are part of a larger conspiracy.

Key Lessons:

• Be aware of the activities of those around you.
• Avoid any involvement in questionable or illegal plans.
• Report any suspicious activity to the authorities.
• Businesses should implement robust compliance programs.

Frequently Asked Questions

Q: What is the difference between conspiracy and being an accomplice?

A: Conspiracy involves an agreement to commit a crime, whereas being an accomplice means assisting in the commission of a crime without being part of the initial agreement.

Q: How can conspiracy be proven in court?

A: Conspiracy can be proven through direct evidence of an agreement or inferred from the actions of the accused before, during, and after the crime.

Q: What is the penalty for conspiracy to commit robbery with homicide?

A: The penalty is reclusion perpetua, an indivisible penalty that will not be affected by the presence of aggravating or mitigating circumstances.

Q: Can someone be guilty of conspiracy even if they didn’t directly participate in the crime?

A: Yes, if they were part of the agreement to commit the crime, the act of one conspirator is the act of all.

Q: What should I do if I suspect someone I know is planning a crime?

A: Report your suspicions to the authorities immediately. Your actions could prevent a crime from occurring and protect yourself from potential legal repercussions.

ASG Law specializes in criminal law and complex litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.