In a case involving the fatal stabbing of Virgilio Revollido, Jr., the Supreme Court affirmed the conviction of Dante Nueva for murder, although it modified certain aspects of the lower court’s decision. Despite questions surrounding the presence of treachery, the Court found that Nueva’s coordinated actions with other assailants constituted a conspiracy, thereby making him accountable for the crime. This ruling underscores the principle that individuals acting in concert towards a common unlawful goal are equally responsible, regardless of the specific role each plays. This ensures justice for the victim and clarifies the responsibilities of co-conspirators under the law.

Shared Intent, Shared Guilt: When Joint Action Leads to a Murder Charge

This case began on the evening of December 29, 2000, when Virgilio Revollido, Jr. was fatally attacked in Caloocan City. Witnesses described a coordinated assault by three individuals: Dante Nueva, Porpirio Maribuhok, and an unidentified assailant known only as John Doe. The central legal question revolves around the degree of Dante Nueva’s culpability, considering the conflicting evidence regarding premeditation and the precise sequence of violent acts.

At trial, witness Alfonso Bacar, Jr. testified that he saw Nueva holding the victim’s arm while another assailant struck him with a piece of wood. Subsequently, both Nueva and John Doe stabbed the victim. The medico-legal report confirmed that Virgilio suffered multiple stab wounds, with two being fatal. Dr. Lagat noted the severity of the injuries, stating they were the direct cause of death. Nueva, on the other hand, offered an alibi, claiming he was working as a bouncer at a local bar at the time of the incident. His defense sought to establish that he could not have been at the crime scene, nor involved in the assault.

The Regional Trial Court (RTC) found Nueva guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed this decision with modifications, increasing the damages awarded to the victim’s heirs. Despite the prosecution arguing the presence of treachery, the Supreme Court re-evaluated the evidence. The Court clarified that **treachery requires a deliberate and conscious choice of means to ensure the execution of the crime without risk to the offender**. Given the spontaneous nature of the attack and the lack of prior planning, the Court found insufficient evidence to establish treachery.

However, the Supreme Court emphasized the existence of **abuse of superior strength**, an aggravating circumstance present in the crime. The victim, unarmed and outnumbered, was jointly attacked by Nueva and his accomplices, who took advantage of their combined physical strength and the element of surprise. Further, despite the lack of proven premeditation, the Court acknowledged the **existence of a conspiracy**. The actions of Nueva, Porpirio, and John Doe demonstrated a common purpose and design to end the victim’s life.

A conspiracy exists when two or more persons come to an agreement concerning the commission of a crime and decide to commit it. Proof of the agreement need not rest on direct evidence as the same may be inferred from the conduct of the parties indicating a common understanding among them with respect to the commission of the offense.

Building on this, the court explained, proof of a formal agreement isn’t needed; a shared understanding inferred from their coordinated actions suffices. Based on these facts, the Supreme Court ruled that the crime was indeed murder, qualified by abuse of superior strength but not by treachery. The court then determined that the absence of both mitigating and aggravating circumstances justified the penalty of reclusion perpetua. Finally, concerning civil liability, the court adjusted the amount of actual damages to P55,438.00, corresponding to the receipts presented. It also awarded the victim’s heirs P1,010,552.40 as compensation for the loss of earning capacity and also the amounts of P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P25,000.00 as exemplary damages.

Consequently, the Supreme Court’s ruling provided important legal guidance on several fronts. First, the requirement for finding treachery, which requires the conscious selection of the method of the attack to ensure its success without any danger to the criminals themselves. Second, It affirms that **conspirators are equally liable for a crime** regardless of their individual acts. Finally, this ruling provides clarity on how loss of earning capacity is calculated, and on the amounts properly awarded as moral and exemplary damages.

FAQs

What was the key issue in this case?	The key issue was determining Dante Nueva’s culpability in the murder of Virgilio Revollido, Jr., considering questions of treachery and the degree of his involvement in the crime.
What was the court’s finding on the existence of treachery?	The Supreme Court found insufficient evidence to establish treachery because the attack appeared spontaneous, and there was no proof of a deliberately chosen method of attack.
How did the court determine that abuse of superior strength existed?	The court noted that the unarmed victim was outnumbered and jointly attacked, with the assailants taking advantage of their combined physical strength and the element of surprise.
What constitutes a conspiracy in the context of this case?	A conspiracy existed because Nueva and his accomplices demonstrated a common purpose to end the victim’s life, with their coordinated actions showing a joint design.
What was the final penalty imposed on Dante Nueva?	Dante Nueva was sentenced to reclusion perpetua, the penalty for murder qualified by abuse of superior strength, in the absence of any mitigating or aggravating circumstances.
How did the court calculate the damages for loss of earning capacity?	The court used the formula: Net Earning Capacity = 2/3 x (80 – age of victim) x (Gross Annual Income – Reasonable Living Expenses), resulting in an award of P1,010,552.40.
What amounts were awarded as moral and exemplary damages?	The victim’s heirs were awarded P50,000.00 as moral damages and P25,000.00 as exemplary damages, in line with current jurisprudence and the presence of abuse of superior strength.
What legal principle does this case highlight regarding co-conspirators?	This case underscores the principle that individuals acting in concert towards a common unlawful goal are equally responsible, regardless of the specific role each plays in the crime.

In summary, the Supreme Court’s decision in People vs. Nueva clarifies the elements of murder and the liabilities of individuals acting in conspiracy. This case illustrates the gravity of engaging in coordinated criminal acts and their profound legal implications.

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. Nueva, G.R. No. 173248, November 3, 2008