Shared Guilt: Understanding Conspiracy in Philippine Murder Cases

TLDR: This case clarifies that in Philippine law, if you conspire with others to commit murder, you are just as guilty as the person who actually delivers the fatal blow, even if your direct participation seems minor. Eyewitness testimony and failing to prove a solid alibi can seal your fate.

G.R. No. 107245, December 17, 1999: PEOPLE OF THE PHILIPPINES VS. FELIPE ABORDO, RICARDO AREBALO, DANIEL ABORDO AND ANICETO JALANDONI

INTRODUCTION

Imagine a scenario: a group of friends gets into a heated argument with someone. Words escalate, and one person in the group, fueled by anger, commits an act of violence, resulting in death. Are the others, who didn’t directly inflict the fatal blow, equally guilty of murder? Philippine law, as illustrated in the case of People vs. Abordo, provides a definitive answer: yes, if conspiracy is proven.

This landmark Supreme Court decision revolves around the tragic death of Porferio Lubiano and the conviction of four individuals: Felipe Abordo, Ricardo Arebalo, Daniel Abordo, and Aniceto Jalandoni. While Felipe Abordo admitted to delivering the fatal blow, the crucial question was whether the other three were also guilty of murder as conspirators. This case serves as a potent reminder of the legal concept of conspiracy and its grave implications in criminal law.

LEGAL CONTEXT: THE DOCTRINE OF CONSPIRACY

The cornerstone of this case is the legal principle of conspiracy. In Philippine criminal law, conspiracy exists when two or more individuals agree to commit a crime and decide to execute it. Article 8 of the Revised Penal Code defines conspiracy, and jurisprudence has consistently held that it doesn’t require a formal agreement. A mutual understanding and a shared criminal design are sufficient.

Article 8 of the Revised Penal Code 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.”

Key legal terms to understand here are:

• Conspiracy: An agreement between two or more people to commit a crime.
• Principals: Those who directly participate in the execution of the act, those who directly force or induce others to commit it, or those who cooperate in the commission of the offense by another act without which it would not have been accomplished. Conspirators are considered principals.

The crucial legal implication of conspiracy is that the act of one conspirator is the act of all. This means that once conspiracy is established, all participants are equally responsible for the crime, regardless of their specific roles. Even if someone’s participation seems minor, like holding the victim while another delivers the fatal blow, they are still considered principals by conspiracy and can be convicted as if they themselves committed the most heinous act.

Previous Supreme Court cases have consistently upheld this doctrine, emphasizing that conspiracy must be proven beyond reasonable doubt, but can be inferred from the actions of the accused before, during, and after the crime. Direct evidence isn’t always necessary; circumstantial evidence pointing to a common criminal design is sufficient.

CASE BREAKDOWN: THE UNRAVELING OF A CONSPIRACY

The story of People vs. Abordo unfolds in a rural setting in Davao. It began with a neighborhood dispute and ended in a brutal killing.

Here’s a chronological breakdown:

• The Conciliation Meeting: Maxima Abordo, mother of Felipe and Daniel Abordo, requested barrio councilman Hermogenes Pan to mediate a dispute. Porferio Lubiano had accused Ricardo Arebalo (Maxima’s nephew) of asking him to steal cacao from Ireneo Longakit. A conciliation meeting was held at the Purok Hall, attended by Lubiano, the Abordos (Felipe, Daniel, and Ciriaco), Ricardo Arebalo, Aniceto Jalandoni, and others.
• Escalation and Suspicion: During the meeting, Aniceto Jalandoni displayed hostility towards Lubiano, even attempting to physically pull him out and checking if he was armed. Hermogenes Pan, the councilman, grew suspicious of the group’s behavior.
• The Deadly Walk to Gaga Creek: After the meeting, Lubiano, accompanied by Felipe and Daniel Abordo, Ricardo Arebalo, and Aniceto Jalandoni, left for Purok 4. Pan secretly followed them.
• The Attack: At Gaga Creek, Pan witnessed Daniel Abordo and Ricardo Arebalo hold Lubiano’s arms while Aniceto Jalandoni struck him with wood. Lubiano fell, and Felipe Abordo dropped a stone on his head.
• Eyewitness Account: Hermogenes Pan, hidden nearby, witnessed the entire gruesome event. He reported it, and Lubiano was found, still alive but with fatal injuries. He died shortly after.
• Trial and Conviction: The four accused were charged with murder. Felipe Abordo admitted to the killing, claiming self-defense. Ricardo Arebalo, Daniel Abordo, and Aniceto Jalandoni claimed alibi. The trial court convicted all four, finding Pan’s eyewitness testimony credible and rejecting the alibis.
• Court of Appeals and Supreme Court: The Court of Appeals affirmed the trial court’s decision, increasing the penalty for Ricardo Arebalo, Daniel Abordo, and Aniceto Jalandoni to reclusion perpetua. The case reached the Supreme Court, which upheld the Court of Appeals’ ruling.

The Supreme Court emphasized the credibility of Hermogenes Pan’s testimony, noting his lack of ill motive and the detailed, consistent nature of his account. The Court stated:

“Where there is no concrete evidence, in our view, to indicate that the witness against the accused has been actuated by any improper motive, and absent any compelling reason to conclude otherwise, the testimony given is ordinarily accorded full faith and credit.”

Regarding conspiracy, the Court highlighted the coordinated actions of the accused:

“Each performed specific acts with such close coordination as to indicate beyond doubt a common criminal design or purpose…Conspiracy to commit the offense is therefore deducible from the acts of the appellants before, during, and after the commission of the crime, which are indicative of a joint purpose, concerted action, and concurrence of sentiments.”

The defense of alibi by Ricardo Arebalo, Daniel Abordo, and Aniceto Jalandoni was dismissed as weak and uncorroborated. The court pointed out the proximity of the locations and the lack of convincing evidence making it impossible for them to be at the crime scene.

PRACTICAL IMPLICATIONS: LESSONS FROM ABORDO

People vs. Abordo reinforces crucial lessons about criminal liability and the concept of conspiracy, with significant practical implications for everyone.

Firstly, it underscores that involvement in a group crime carries heavy consequences for all participants, even those who don’t directly commit the most violent acts. If you are part of a group that conspires to commit a crime, you are legally on the hook as much as the main perpetrator.

Secondly, eyewitness testimony remains a powerful form of evidence in Philippine courts. If a witness is deemed credible, their account can significantly influence the outcome of a case. In this instance, Hermogenes Pan’s testimony was pivotal in securing the convictions.

Thirdly, alibi is a notoriously weak defense, especially if not convincingly proven and corroborated. Simply claiming to be elsewhere isn’t enough; you must demonstrate it was physically impossible for you to be at the crime scene.

Key Lessons from People vs. Abordo:

• Choose your company wisely: Association with individuals involved in criminal activities can have severe legal repercussions, especially if conspiracy is involved.
• Be mindful of your actions in groups: Even if you don’t directly commit the crime, participating in actions that contribute to it can make you equally liable under the principle of conspiracy.
• Eyewitness accounts matter: Ensure your actions are lawful, especially in public, as eyewitnesses can play a critical role in legal proceedings.
• Alibi requires solid proof: If you rely on alibi, gather substantial evidence and credible witnesses to support your claim.

FREQUENTLY ASKED QUESTIONS (FAQs)

Q1: What exactly does conspiracy mean in legal terms?

A: Conspiracy is an agreement between two or more people to commit a crime. It doesn’t require a formal, written plan. A shared understanding and intent to commit the crime are sufficient.

Q2: If I didn’t directly kill anyone, can I still be convicted of murder through conspiracy?

A: Yes, absolutely. In Philippine law, if you are proven to be a conspirator in a murder, you are considered a principal and can be convicted of murder, even if you didn’t personally inflict the fatal wound.

Q3: What kind of evidence is needed to prove conspiracy?

A: Conspiracy can be proven through direct evidence (like testimonies about the agreement) or circumstantial evidence (actions of the accused before, during, and after the crime that suggest a common plan).

Q4: Is alibi a strong defense in court?

A: Generally, no. Alibi is considered a weak defense unless it is ironclad and proven beyond doubt that it was physically impossible for the accused to be at the crime scene. It needs strong corroboration from independent witnesses.

Q5: What is ‘reclusion perpetua’?

A: Reclusion perpetua is a penalty under Philippine law, translating to life imprisonment. It is a severe punishment for grave offenses like murder.

Q6: How does eyewitness testimony affect a case?

A: Eyewitness testimony can be very influential if the witness is deemed credible by the court. A clear, consistent, and believable eyewitness account can significantly strengthen the prosecution’s case.

Q7: What should I do if I am wrongly accused of conspiracy?

A: Immediately seek legal counsel. A lawyer specializing in criminal law can assess your situation, advise you on the best course of action, and build a strong defense to protect your rights.

ASG Law specializes in Criminal Defense and Philippine Litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.