The Essence of Conspiracy: How Shared Intent Leads to Shared Liability

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G.R. No. 129528, June 08, 2000

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Imagine a scenario where two individuals, fueled by alcohol and resentment, jointly assault another person, each wielding a different weapon. Can both be held equally accountable, even if one argues he didn’t inflict the fatal blow? This is the core question explored in People v. Carillo, a Philippine Supreme Court decision that delves into the legal concept of conspiracy and its implications for criminal liability.

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The case revolves around the fatal stabbing of Ritchie P. Sumud-ong. Accused-appellant Oscar Carillo, along with Eduardo Candare, was charged with murder. The prosecution argued that both men, acting in conspiracy, attacked Sumud-ong. Carillo, however, claimed that only Candare stabbed the victim. The Supreme Court ultimately upheld Carillo’s conviction, underscoring the principle that when conspiracy is proven, the act of one conspirator is the act of all.

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Understanding Conspiracy in Philippine Law

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Conspiracy is a critical concept in Philippine criminal law. It essentially means that when two or more people agree to commit a crime and decide to pursue it, each person is responsible for the actions of the others in carrying out the plan. This principle is rooted in Article 8 of the Revised Penal Code, which defines conspiracy and proposal to commit a felony.

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Article 8 states: “Conspiracy and proposal to commit felony are punishable only in the cases in which the law specially provides a penalty therefor. A conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.”n

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To prove conspiracy, it is not necessary to show a formal agreement. Conspiracy can be inferred from the actions of the accused, showing a common purpose and design. This is often demonstrated through evidence of coordinated actions, mutual assistance, and a shared understanding of the criminal objective.

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For example, imagine two individuals planning to rob a bank. One provides the getaway car, while the other enters the bank to carry out the robbery. Even if the driver remains outside, he is still considered a conspirator and equally liable for the crime.

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The Story of Ritchie Sumud-ong: A Case of Conspiracy

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The events leading to Ritchie Sumud-ong’s death paint a grim picture. On July 10, 1996, Sumud-ong and his cousin, Richard Pabate, were walking home after playing basketball. They encountered Oscar Carillo and Eduardo Candare, who had been drinking. Without warning, Carillo and Candare attacked Sumud-ong. Pabate testified that Carillo used an ice pick-like weapon, while Candare wielded a hunting knife.

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Danilo Anino, another eyewitness, corroborated Pabate’s account, stating that the attack was sudden and unprovoked. Sumud-ong sustained two stab wounds and later died from his injuries.

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The case proceeded through the following steps:

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• An amended information charged Carillo and Candare with murder.

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• Carillo pleaded not guilty. Candare evaded arrest initially.

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• The Regional Trial Court (RTC) found Carillo guilty of murder, based on the testimonies of the prosecution witnesses and the medical evidence.

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The RTC emphasized the suddenness of the attack and the use of different weapons, indicating a coordinated effort. As the trial court noted, both accused, “without any warning suddenly thrust his ice pick or similar weapon on the chest of Ritchie Sumud-ong… This was immediately followed with a thrust by Eduardo Candare with his 3-[cm.] wide knife… The two wounds resulted in the death of Ritchie Sumud-ong.”

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Carillo appealed the RTC’s decision, arguing that only Candare stabbed the victim and that the prosecution’s eyewitnesses were unreliable. He also questioned whether the medical certificate proved that the smaller injury was caused by an ice pick.

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The Supreme Court, however, affirmed Carillo’s conviction. The Court found the testimonies of the prosecution witnesses credible and consistent with the medical evidence. The Court also highlighted the inconsistencies in the testimonies of the defense witnesses.

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The Court emphasized the significance of the medical findings, noting that