In Freddie Cabildo v. People, the Supreme Court clarified the requirements for proving conspiracy in attempted homicide cases. The Court ruled that conspiracy can be inferred from the coordinated actions of the accused before, during, and after the commission of the crime, demonstrating a shared purpose and intent. This decision reinforces that even without a prior explicit agreement, a common criminal design can be established through the collective behavior of the involved parties, affecting the culpability and sentencing of each participant.

From Commotion to Conspiracy: When Helping a Friend Becomes a Crime

The case began on the evening of March 19, 1999, in Barangay Tenga-Tenga, Cuyo, Palawan, when Freddie Cabildo and his companions, Jesus Palao, Jr. and Rodrigo Abian, confronted Joy Herrera, a tricycle driver. Rocky Daquer intervened, only to become the target himself when Palao threatened him and brandished a knife. The situation escalated as the group chased Daquer, leading to a stabbing. The legal question centered on whether Cabildo and his co-accused acted in conspiracy to commit homicide, and whether their actions constituted frustrated or only attempted homicide. This question hinged on proving shared intent and the extent of the injuries inflicted.

The Regional Trial Court (RTC) initially found Cabildo and his co-accused guilty of frustrated homicide. The Court of Appeals (CA), however, modified the conviction to attempted homicide, reasoning that the injuries inflicted on Daquer were not life-threatening. The Supreme Court (SC) affirmed the CA’s decision, emphasizing the importance of positive witness testimony and the inference of conspiracy from the defendants’ actions. This ruling highlights the significance of proving shared intent in establishing criminal liability for conspiracy.

One of the critical aspects of the case was the determination of conspiracy. The Supreme Court relied on established jurisprudence defining conspiracy as existing “when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.” Crucially, the agreement does not need to be proven directly but can be inferred from the conduct of the parties involved. The Court noted that:

The agreement need not be proven by direct evidence; it may be inferred from the conduct of the parties before, during, and after the commission of the offense, pointing to a joint purpose and design, concerted action, and community of interest.

In Cabildo’s case, the Court found that his actions, alongside those of Palao and Abian, demonstrated a clear intent to harm Daquer. Specifically, Cabildo’s act of grabbing Daquer’s jacket, causing him to fall, provided Palao the opportunity to stab Daquer. This coordinated action indicated a shared criminal design. The Court stated:

Palao unequivocally announced his intention to kill Daquer and immediately drew his batangas knife and ran after the latter, while Cabildo and Abian readily agreed with this desire by pursuing Daquer and actually catching up with him. Cabildo’s act of grabbing Daquer’s jacket and pulling him to the ground provided the opportunity for Palao to stab him twice. After getting hit on the second try Cabildo and Abian readily proceeded to maul him together with Palao.

The defense argued that the attack on Daquer was a spontaneous act of violence without prior conspiracy. However, the Court rejected this argument, emphasizing that Palao’s threat to kill Daquer, coupled with the subsequent coordinated actions of Cabildo and Abian, clearly indicated a conspiracy. The evidence presented demonstrated that the accused acted with a common purpose, making each of them liable for the crime committed.

Another significant point in the case was the distinction between frustrated homicide and attempted homicide. The determination of the crime’s stage depended on the severity of the injuries inflicted and whether the accused performed all the acts of execution that would have resulted in the victim’s death. The Supreme Court, affirming the Court of Appeals, found that the stab wound sustained by Daquer was not life-threatening, as evidenced by the medical certificate and the doctor’s testimony. Therefore, the crime was only at the attempted stage.

The Revised Penal Code provides the framework for distinguishing between these stages. Article 6 of the Revised Penal Code defines attempted felony as when the offender commences the commission of a felony directly by overt acts, and does not perform all the acts of execution which should produce the felony by reason of some cause or accident other than his own spontaneous desistance. In contrast, frustrated felony occurs when the offender performs all the acts of execution which would produce the felony as a consequence but which, nevertheless, do not produce it by reason of causes independent of the will of the perpetrator.

The Supreme Court also addressed the credibility of witnesses. The petitioner, Cabildo, challenged the consistency of prosecution witnesses, particularly regarding whether Herrera was a driver or a passenger of the tricycle. The Court dismissed these challenges, stating that such inconsistencies were minor and did not affect the essential elements of the crime. The Court reiterated the principle that the testimony of a single credible witness can be sufficient for conviction. In this case, the victim’s testimony, positively identifying his assailants and describing the manner in which they committed the crime, was deemed credible and reliable.

The penalty imposed on Cabildo reflected the Court’s finding of attempted homicide. The imposable penalty for attempted homicide is prision correccional, which is two degrees lower than reclusion temporal, the penalty for homicide. Taking into account the absence of mitigating or aggravating circumstances, the Court imposed a penalty within the medium period of prision correccional. The indeterminate sentence ranged from four months of arresto mayor to four years and two months of prision correccional, providing a nuanced approach to sentencing based on the specific facts of the case.

This case serves as a significant reminder of the legal consequences of participating in a group attack, even if one’s specific role seems minor. The doctrine of conspiracy holds each participant accountable for the actions of the others, provided there is evidence of a common criminal design. This principle deters individuals from engaging in or supporting violent acts, as they risk being held liable for the full extent of the crime committed by the group. Furthermore, the distinction between attempted and frustrated homicide underscores the importance of proving the severity of injuries and the intent to kill in determining criminal liability.

The Cabildo ruling reaffirms that conspiracy can be inferred from coordinated actions and that the severity of injuries dictates the stage of the crime. It highlights the importance of witness credibility and the prosecution’s burden to prove intent beyond reasonable doubt. This decision provides valuable guidance for legal practitioners and clarifies the standards for establishing criminal liability in cases involving multiple actors and varying degrees of harm.

FAQs

What was the key issue in this case?	The key issue was whether the actions of Freddie Cabildo and his co-accused constituted conspiracy to commit homicide, and whether the crime committed was frustrated or attempted homicide. The court needed to determine if there was a shared intent and if the injuries were life-threatening.
What is the legal definition of conspiracy?	Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. The agreement doesn’t need direct proof but can be inferred from the parties’ conduct before, during, and after the offense.
How did the court determine there was a conspiracy in this case?	The court inferred conspiracy from the coordinated actions of Cabildo, Palao, and Abian. These included Palao’s threat to kill Daquer, Cabildo grabbing Daquer’s jacket, and Abian chasing Daquer, all of which facilitated the stabbing.
What is the difference between attempted and frustrated homicide?	Attempted homicide occurs when the offender commences the commission of a felony but does not perform all the acts of execution due to reasons other than their own spontaneous desistance. Frustrated homicide happens when the offender performs all acts of execution but fails to produce the felony due to independent causes.
Why was the crime classified as attempted homicide instead of frustrated homicide?	The crime was classified as attempted homicide because the stab wound inflicted on Rocky Daquer was not life-threatening. Medical evidence indicated that the wound was superficial and did not hit any vital organs.
Is the testimony of a single witness sufficient for conviction?	Yes, the testimony of a single credible witness is sufficient for conviction. The court found the victim’s testimony in this case to be credible, positively identifying his assailants and describing the crime.
What was the penalty imposed on Freddie Cabildo?	Freddie Cabildo was sentenced to an indeterminate penalty of four months of arresto mayor, as minimum, to four years and two months of prision correccional, as maximum. This penalty reflects the crime of attempted homicide without any mitigating or aggravating circumstances.
What is the significance of this case for future legal proceedings?	This case clarifies the standards for proving conspiracy in attempted homicide cases and emphasizes the importance of intent. It also distinguishes between attempted and frustrated homicide based on the severity of injuries and the acts of execution performed.

The Cabildo case underscores the importance of understanding the legal principles surrounding conspiracy and attempted crimes. The coordinated actions of individuals can lead to shared criminal liability, even without a prior explicit agreement. Furthermore, the specific facts of each case, particularly the nature and extent of injuries, are crucial in determining the appropriate charges and penalties.

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: Freddie Cabildo v. People, G.R. No. 189971, August 23, 2010