In People v. Callao, the Supreme Court affirmed the conviction of Hesson Callao for murder, emphasizing the principle of conspiracy and its implications on criminal liability. The court clarified that even if one conspirator’s direct actions might individually constitute an impossible crime, the presence of a conspiracy makes all involved parties equally responsible for the overarching crime committed. This case underscores how Philippine law holds individuals accountable for the collective actions agreed upon within a conspiracy, regardless of the specific role each person plays in the final act.

When a Pig Feast Leads to a Murder Conviction: Unpacking Conspiracy and Intent

The case revolves around the gruesome murder of Fernando Adlawan, where Hesson Callao was convicted based on the testimony of a lone witness, Sario Joaquin. Sario recounted how Hesson and Junello Amad conspired to kill Fernando. Junello initiated the attack, and Hesson followed by stabbing the victim and mutilating the body. A particularly disturbing detail revealed that the heart and liver of the deceased were fed to a pig. Hesson appealed his conviction, arguing that his actions constituted an impossible crime, as Fernando was allegedly already dead when he inflicted the final blows. He further contested the finding of conspiracy. The central legal question was whether Hesson could be held liable for murder, given his defense of impossible crime and the challenge to the conspiracy finding.

The Supreme Court, in its decision, firmly rejected Hesson’s arguments. The Court emphasized the credibility of Sario Joaquin’s testimony, noting that despite being the sole witness, his straightforward account of the events was sufficient to establish Hesson’s guilt beyond a reasonable doubt. It is a well-established principle that the testimony of a single witness, if found credible, can sustain a conviction, especially when it bears the hallmarks of truth and sincerity. As the Court stated in People v. Hillado:

xxx Thus, the testimony of a lone eyewitness, if found positive and credible by the trial court, is sufficient to support a conviction especially when the testimony bears the earmarks of truth and sincerity and had been delivered spontaneously, naturally and in a straightforward manner. Witnesses are to be weighed, not numbered. Evidence is assessed in terms of quality and not quantity. Therefore, it is not uncommon to reach a conclusion of guilt on the basis of the testimony of a lone witness.

Building on this principle, the Court found no evidence of ill motive on Sario’s part that would impel him to falsely accuse Hesson, thus reinforcing the reliability of his testimony. Additionally, Hesson’s flight from the scene of the crime and subsequent efforts to evade arrest further weakened his claim of innocence, suggesting a consciousness of guilt. This approach contrasts with the behavior expected of an innocent person, who would typically take immediate action to clear their name. It is also a settled rule that findings of the trial court on the credibility of witnesses are given great weight, as the trial court has the unique opportunity to observe the demeanor of witnesses and assess their credibility firsthand. Therefore, the Supreme Court saw no reason to overturn the trial court’s assessment.

The defense of impossible crime was also thoroughly addressed. Hesson contended that he could not be convicted of murder because Fernando was already dead when he stabbed him, rendering the act legally impossible. The Revised Penal Code defines an impossible crime in Article 4, paragraph 2:

ART. 4. Criminal liability. – Criminal liability shall be incurred:

x x x x

2. By any person performing an act which would be an offense against persons or property, were it not for the inherent impossibility of its accomplishment or on account of the employment of inadequate to ineffectual means.

However, the Court found that the defense failed to sufficiently establish that Fernando was indeed dead before Hesson stabbed him. While Sario testified that he believed Fernando was dead after Junello’s attack, this was based on his observation of Fernando lying motionless on the ground. No further verification, such as checking for a pulse, was conducted. In light of this, the Court reasoned that Sario’s perception could have been an erroneous assessment made amidst the chaos and stress of the moment. More critically, the Court highlighted the presence of conspiracy, which negated the impossible crime defense. Conspiracy, in legal terms, arises when two or more individuals agree to commit a felony and decide to pursue it. The essence of conspiracy is the unity of action and purpose.

The court emphasized that direct proof of conspiracy is not essential; it can be inferred from the actions of the accused before, during, and after the commission of the crime. In this case, the series of acts by Hesson and Junello demonstrated a shared criminal objective. The Court quoted the CA’s description of the events:

xxx First, Amad and Callao hatched the plan to kill Fernando in the flea market; thereafter, they went to Fernando’s house in Colasisi. Amad pretended to borrow a lighter from Fernando who, after handing out a lighter, was unknowingly struck on the nape. Then, Amad hacked Fernando. After Fernando fell on the ground, Callao jumped in and stabbed Fernando’s chest with a knife. Thereafter, Callao sliced open Fernando’s chest and took out his heart. Amad then took his turn and sliced up Fernando’s body to take out his liver. All these acts clearly reveal conspiracy. Amad and Callao committed what they agreed to do – to kill Fernando.

Given the existence of conspiracy, the Court applied the principle that the act of one conspirator is the act of all. This principle means that all conspirators are equally liable, regardless of their individual participation in the crime. The landmark case of People v. Peralta clearly articulates this point:

Once an express or implied conspiracy is proved, all of the conspirators are liable as co-principals regardless of the extent and character of their respective active participation in the commission of the crime or crimes perpetrated in furtherance of the conspiracy because in contemplation of law the act of one is the act of all.

Therefore, even if Hesson’s act of stabbing Fernando might have been considered an impossible crime in isolation, the presence of conspiracy made him equally liable for the murder committed by Junello. The Court thus affirmed the conviction for murder, qualified by treachery. Treachery exists when the offender employs means and methods to ensure the execution of the crime without risk to themselves and without giving the victim a chance to defend themselves. Here, the attack on Fernando was sudden and unexpected, depriving him of any opportunity to resist or escape.

The penalty for murder under Article 248 of the Revised Penal Code is reclusion perpetua to death. Since there were no aggravating or mitigating circumstances, the Court upheld the sentence of reclusion perpetua. With respect to damages, the Court affirmed the CA’s award of civil indemnity and moral damages of P75,000 each, exemplary damages of P30,000, and funeral expenses of P15,000. All monetary awards would earn interest at the legal rate of six percent (6%) per annum from the date of finality of the decision until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether Hesson Callao could be convicted of murder despite his defense that the victim was already dead when he stabbed him, potentially making it an impossible crime, and whether a conspiracy existed between him and Junello Amad.
What is an impossible crime under Philippine law?	An impossible crime, as defined in Article 4(2) of the Revised Penal Code, is an act that would be an offense against persons or property but cannot be accomplished due to inherent impossibility or the use of inadequate means.
How did the court define conspiracy in this case?	Conspiracy exists when two or more persons agree to commit a felony and decide to commit it; it requires unity of action and purpose, which can be inferred from the acts of the accused before, during, and after the commission of the crime.
What is the legal effect of proving conspiracy?	Once conspiracy is proven, all conspirators are liable as co-principals, regardless of their individual participation in the crime; in contemplation of law, the act of one is the act of all.
Why was Hesson Callao convicted of murder despite his impossible crime defense?	The court ruled that the defense failed to sufficiently prove that the victim was already dead when Hesson stabbed him, and more importantly, the existence of a conspiracy between Hesson and Junello made Hesson liable for the acts of Junello.
What evidence supported the finding of conspiracy in this case?	The planning of the crime at the flea market, the coordinated actions of Junello and Hesson at the victim’s house, and the overall unity of purpose to kill Fernando Adlawan demonstrated a conspiracy.
What is the significance of the lone witness’s testimony in this case?	The testimony of the lone witness, Sario Joaquin, was deemed credible and sufficient to establish Hesson’s guilt beyond a reasonable doubt, as it was straightforward, spontaneous, and without any apparent ill motive.
What damages were awarded to the victim’s heirs?	The court awarded civil indemnity and moral damages of P75,000 each, exemplary damages of P30,000, and funeral expenses of P15,000; all monetary awards earned interest at the legal rate of six percent (6%) per annum from the date of finality of the decision until fully paid.

The People v. Callao case serves as a crucial reminder of the application of conspiracy in criminal law, reinforcing that participation in a joint criminal enterprise carries significant legal consequences. The decision highlights the importance of proving conspiracy beyond reasonable doubt and its effect on individual liability. This case provides insight into how Philippine courts approach complex criminal scenarios involving multiple actors and defenses based on the impossibility of committing the crime.

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 vs. Hesson Callao y Marcelino, G.R. No. 228945, March 14, 2018