The Supreme Court affirmed the conviction of Rolito Gerero, Alfie Espinosa, and Renato Bartolome for murder, emphasizing that when individuals act together in a crime, their collective actions demonstrate a conspiracy where each is responsible for the actions of the group. This ruling reinforces that involvement in a concerted criminal act makes one liable as if they acted alone, upholding the principle that participation in a group endeavor leads to equal culpability for all participants. This decision clarifies the criteria for establishing conspiracy in murder cases, focusing on the collective actions and shared intent of the accused.

From Workplace Envy to Gruesome End: When Does Collective Action Imply Conspiracy?

In Rodriguez, Rizal, Robert Glee was murdered by a group including Frankie Gerero, Rolito Gerero, Alfie Espinosa, Christopher Gerero, and Renato Bartolome. The gruesome crime involved the group barging into Robert’s house and repeatedly attacking him with bolos, culminating in his decapitation. The central legal question revolved around whether the actions of the accused constituted a conspiracy, making each member equally liable for the murder. The lower courts found Rolito, Alfie, and Renato guilty, a decision that was appealed and eventually affirmed by the Supreme Court, which focused primarily on the element of conspiracy.

The Supreme Court’s analysis began by defining conspiracy, explaining that it exists when two or more persons agree to commit a felony and decide to pursue it. According to the court, the essence of conspiracy is the unity of action and purpose, meaning that there must be a shared intent among the individuals involved. The Court cited Quidet v. People, emphasizing that:

Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. The essence of conspiracy is the unity of action and purpose. Its elements, like the physical acts constituting the crime itself, must be proved beyond reasonable doubt. When there is conspiracy, the act of one is the act of all. Conspiracy can be inferred from and established by the acts of the accused themselves when said acts point to a joint purpose and design, concerted action and community of interests. However, in determining whether conspiracy exists, it is not sufficient that the attack be joint and simultaneous for simultaneousness does not of itself demonstrate the concurrence of will or unity of action and purpose which are the bases of the responsibility of the assailants. What is determinative is proof establishing that the accused were animated by one and the same purpose.

In this case, the lower courts found clear evidence of conspiracy. The accused acted together to barge into Robert’s residence, with some entering through the front door and others through the back. This coordinated entry was followed by a joint attack on Robert, using bolos. Even after Robert fled, the group pursued him, continuing their assault until his death. The Court of Appeals highlighted that these concurrent actions demonstrated a shared intent to commit murder, reinforcing the idea that in a conspiracy, each person’s actions contribute to the overall crime, making them equally responsible.

The presence of conspiracy significantly impacts the legal consequences for each participant. If a conspiracy is proven, each conspirator is held equally accountable for the actions of the group. This principle is rooted in the idea that by agreeing to commit a crime, each participant assumes responsibility for the actions of others in furtherance of that crime. In this case, because the accused were found to have conspired to murder Robert Glee, each was held responsible for the entirety of the act, including the gruesome decapitation.

While the Court of Appeals did not find sufficient evidence to support the qualifying circumstances of abuse of superior strength and evident premeditation, it did acknowledge the presence of another circumstance: outraging or scoffing at the victim’s person or corpse. This circumstance, outlined in Article 248 of the Revised Penal Code (RPC), applies when the offender performs acts that degrade or show contempt for the victim, either before or after death. The Court referenced the decapitation of Robert’s head and its subsequent disposal in the mud as clear indicators of such outrage.

The Court of Appeals accurately noted that all elements of murder were present in the case, stating:

In the case at bench, all of the above mentioned elements of the crime of murder were proven beyond reasonable doubt by the prosecution. First, it was established that Robert, the victim, was killed. Second, Accused-Appellants and Accused Frankie and Christopher killed the victim as testified by the prosecution witnesses, who saw how the victim was simultaneously hacked and stabbed by them. Third, the killing was attended by the qualifying circumstance of outraging or scoffing at the victim’s person or corpse. It was established that after the victim was hacked and stabbed, Accused Frankie decapitated his head and threw the same in the “lubluban ng kalabaw”. It is well-settled that mere decapitation of the victim’s head constitute outraging or scoffing at the corpse of the victim, thus qualifying the killing to murder. Lastly, the killing of the victim neither constituted parricide nor infanticide.

Given the presence of the qualifying circumstance of cruelty, the penalty for murder, under Article 248 of the RPC, should have been death. However, considering the enactment of Republic Act No. 9346, which prohibits the imposition of the death penalty, the sentence was reduced to reclusion perpetua without eligibility for parole. Additionally, the Supreme Court adjusted the awards for civil indemnity, moral damages, and exemplary damages to P100,000.00 each, and awarded temperate damages of P50,000.00, aligning the judgment with prevailing jurisprudence.

FAQs

What was the key issue in this case?	The primary issue was whether the actions of the accused constituted a conspiracy to commit murder, making each of them equally liable for the crime. The court examined the evidence to determine if a shared intent and coordinated action existed among the accused.
What is the definition of conspiracy in legal terms?	Conspiracy is defined as an agreement between two or more individuals to commit a felony, coupled with a decision to commit it. The essence of conspiracy is the unity of action and purpose among the participants.
How does conspiracy affect the liability of each accused?	When a conspiracy is proven, each conspirator is held equally liable for the actions of the group, as if they had personally committed the entire crime. This means that the act of one conspirator is considered the act of all.
What was the qualifying circumstance in this murder case?	The qualifying circumstance in this case was outraging or scoffing at the victim’s person or corpse. This was evidenced by the decapitation of the victim’s head and its subsequent disposal.
What is the significance of Republic Act No. 9346 in this case?	Republic Act No. 9346 prohibits the imposition of the death penalty. Although the presence of cruelty as an aggravating circumstance would have warranted the death penalty, the court imposed reclusion perpetua without eligibility for parole due to this law.
What damages were awarded to the victim’s heirs in this case?	The Supreme Court awarded civil indemnity, moral damages, and exemplary damages, each increased to P100,000.00. Additionally, the heirs were entitled to temperate damages in the amount of P50,000.00.
What is the rate of interest applied to the monetary awards?	All monetary awards in this case will earn interest at the rate of six percent (6%) per annum from the date of finality of the Resolution until fully paid.
What was the final decision of the Supreme Court?	The Supreme Court affirmed the Court of Appeals’ decision finding the accused guilty of murder, with modifications to increase the amounts of civil indemnity, moral damages, and exemplary damages. The Court also added an award for temperate damages and clarified that the accused are not eligible for parole.

This case underscores the serious consequences of participating in group violence. The Supreme Court’s decision serves as a reminder that individuals who join in a conspiracy to commit a crime will be held fully accountable for the resulting harm. It highlights the importance of understanding the legal implications of one’s actions when associating with others in potentially criminal activities.

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. FRANKIE GERERO, ET AL., G.R. No. 213601, July 27, 2016