The Supreme Court, in People v. Go-od, clarified that when a group acts together with a common purpose to commit murder, each member is equally responsible, regardless of who inflicted the fatal blow. This means that even if an accused didn’t directly cause the victim’s death, their participation in the coordinated attack makes them guilty as a co-principal. The ruling emphasizes that conspiracy demonstrates a shared criminal intent, making all participants liable. This liability holds even if one of the attackers is injured during the assault, as long as their initial actions contributed to the victim’s death.

When a Hunt for a Goat Turns Deadly: Unraveling Conspiracy in Cataingan

This case originates from an incident on May 8, 1991, in Cataingan, Masbate, where Aladino Ygot was fatally attacked by Alejandro Go-od, Nestor Go-od, Sancho Go-od, Rufo Go-od, and Empe Go-od. The Go-ods confronted Ygot while he was searching for a missing goat, leading to a violent confrontation. According to the prosecution, the Go-ods emerged from a banana grove and simultaneously attacked Ygot with bolos and a spear, inflicting multiple wounds. The attack resulted in Ygot’s instantaneous death. The accused, Nestor Go-od, appealed his conviction, arguing that he was wounded by the victim during the incident, preventing him from inflicting fatal injuries.

The central legal question revolves around whether Nestor Go-od’s claim of being wounded and incapacitated during the attack absolves him of criminal liability, considering the established fact that he was part of a group that conspired to commit the crime. The trial court found Nestor Go-od guilty of murder, a decision he contested. The Supreme Court had to examine the evidence to determine if conspiracy was proven and whether Nestor’s injuries negated his involvement in the crime. The court also deliberated on the presence of aggravating circumstances, such as treachery and abuse of superior strength, which influenced the penalty imposed.

The Supreme Court affirmed the lower court’s decision, emphasizing the principle of conspiracy. According to the Court, conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. The prosecution successfully demonstrated that Nestor Go-od and his companions acted in concert with a common design to kill Aladino Ygot. Witness testimony and the nature of the attack supported this finding, showing a coordinated effort to overwhelm the victim. The Court cited People vs. Baniel, 275 SCRA 472 (1997), stating that the acts of the accused-appellant and his companions manifestly disclose their joint purpose and design, concerted action and community of interest. This meant that each participant was equally responsible for the crime, regardless of their individual actions.

Nestor Go-od’s defense hinged on the argument that he was wounded by Aladino Ygot during the attack and therefore could not have contributed to the fatal injuries. However, the Court found this argument unpersuasive. The Supreme Court highlighted that even if Nestor Go-od was injured, the fact remained that he was part of the initial assault. This initial involvement established his participation in the conspiracy, making him liable as a co-principal. The court referenced People vs. Obello, 284 SCRA 79 (1998), which stated that once conspiracy has been established, it is unnecessary to pinpoint who among the accused inflicted the fatal blow.

Furthermore, the Supreme Court addressed the presence of aggravating circumstances. The trial court had appreciated both treachery and abuse of superior strength. The Supreme Court clarified that while treachery was indeed present, it absorbed abuse of superior strength. Treachery exists when the offender commits any of the crimes against the person, employing means, methods or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from the defense which the offended party might make, as defined in Article 14, paragraph 16 of the Revised Penal Code.

The court highlighted that the sudden and unexpected attack on Aladino Ygot, who was unarmed and caught off guard, constituted treachery. However, abuse of superior strength, manifested by the five assailants against one unarmed victim, was absorbed by treachery, as detailed in People vs. Datun, 272 SCRA 380 (1997). Therefore, only treachery was considered in determining the appropriate penalty.

Concerning the penalty, the murder occurred before the enactment of Republic Act No. 7659, which increased the penalties for certain crimes. Thus, the applicable provision was Article 248 of the Revised Penal Code, which prescribed a penalty of reclusion temporal in its maximum period to death for murder. The trial court sentenced Nestor Go-od to reclusion perpetua, the medium period of the imposable penalty. The Supreme Court affirmed this sentence as appropriate under the circumstances.

In addition to the prison sentence, the Supreme Court addressed the civil liabilities of the accused. The Court upheld the award of P50,000.00 as civil indemnity, which is a standard amount in murder cases, as supported by prevailing jurisprudence cited in People vs. Robles, G.R. No. 124300, March 25, 1999. Moral damages of P30,000.00 were also deemed reasonable, considering the pain and suffering experienced by the victim’s widow, as recognized in People vs. Gonzales, G.R. No. 130507, July 28, 1999. However, the Court deleted the award of exemplary damages, as there was no additional aggravating circumstance beyond treachery.

The Supreme Court also adjusted the award for loss of earning capacity. The Court calculated this amount based on the victim’s age, income, and life expectancy using the formula provided in People vs. Verde, G.R. No. 119077, February 10, 1999:

Net Earning Capacity = Life Expectancy x (Gross Annual Income – Living Expenses)

The court used the following formula, that loss of earning capacity is computed based on the following formula:

Net Earning Capacity (X)	=	life expectancy [2/3 (80-age at death)]	x	Gross Annual Income (GAI)	–	Living expenses (50% of GAI)
X	=	2 (80-31) 3	x	48,000.00	–	24,000.00
X	=	33	x	24,000.00
Net Earning Capacity = P 792,000.00

Based on this formula, the Court calculated the loss of earning capacity to be P792,000.00. This amount was awarded to the heirs of Aladino Ygot to compensate for the financial loss resulting from his untimely death. This comprehensive approach to civil liability ensures that the victim’s family receives adequate compensation for their loss.

FAQs

What was the key issue in this case?	The key issue was whether Nestor Go-od’s participation in a group attack resulting in the victim’s death made him liable for murder, even if he claimed he didn’t inflict the fatal wound due to being injured himself during the attack. The court focused on establishing the presence of conspiracy and its implications on individual liability within the group.
What is the legal definition of conspiracy as applied in this case?	Conspiracy, as applied here, refers to an agreement between two or more individuals to commit a felony, with a shared decision to execute the crime. Once conspiracy is proven, the act of one conspirator becomes the act of all, making each participant equally liable.
How did the court address the claim that Nestor Go-od was injured during the attack?	The court acknowledged that Nestor Go-od might have been injured during the attack but emphasized that his initial participation in the assault and the established conspiracy made him liable regardless. The fact that he joined the attack was enough to implicate him in the crime.
What is the significance of “treachery” in this case?	Treachery is a qualifying circumstance that elevates a killing to murder. In this case, the sudden and unexpected nature of the attack, which prevented the victim from defending himself, constituted treachery.
Why was abuse of superior strength not considered a separate aggravating circumstance?	Abuse of superior strength was not considered separately because it was absorbed by treachery. The court explained that when treachery is present, it encompasses the advantage gained from the disparity in strength or numbers, preventing it from being appreciated as a distinct aggravating factor.
What was the basis for calculating the loss of earning capacity?	The loss of earning capacity was calculated based on the victim’s age, income, and life expectancy, using a formula that considers gross annual income and living expenses. This calculation aimed to compensate the victim’s heirs for the financial loss resulting from his untimely death.
What is civil indemnity, and why was it awarded in this case?	Civil indemnity is a monetary compensation awarded to the victim’s heirs in a criminal case to acknowledge the damage caused by the crime. It is separate from other forms of damages and is typically a fixed amount. The court awarded it here to recognize the loss suffered by the victim’s family due to his death.
What were the key pieces of evidence that supported the conviction?	Key evidence included eyewitness testimonies that described the coordinated attack by the group, the nature and extent of the victim’s injuries, and the established motive for the crime. This evidence collectively supported the finding of conspiracy and the guilt of the accused.

The ruling in People v. Go-od serves as a stern reminder of the legal consequences of participating in group crimes. It underscores the principle that those who conspire to commit unlawful acts will be held accountable, regardless of their specific role in the actual crime. This case reinforces the importance of understanding the legal implications of one’s actions and the potential liabilities that arise from collective criminal behavior.

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 of the Philippines, Plaintiff-Appellee, vs. Alejandro Go-od (Deceased) Nestor Go-od, Sancho Go-od, Rufo Go-od and Empe Go-od, Accused, Nestor Go-od, Accused-Appellant., G.R. No. 134505, May 09, 2000