United States vs Eguia (1909)

Respondents, Lino Eguia Lim Buanco (Lim Buanco) and Luciano de los Reyes Dicta
Ponente, Elliott WoN joint decision was valid
YES. Each sentence was based on evidence from each trial. The purpose of the
Provisions (According to the syllabi) separate trial was served and no rights were violated. The joint decision is a matter of
Art. 17. Principals. — The following are considered principals: convenience and there is no reason it should not be approved.
1. Those who take a direct part in the execution of the act;
2. Those who directly force or induce others to commit it; WoN defendants not testifying as witnesses on their own behalf violates their
3. Those who cooperate in the commission of the offense by another act constitutional right
without which it would not have been accomplished. NO. This is only a consideration for a court with a jury. Without a jury, the judge
considers whether the fact can be used as an evidential fact. In this case, it was not.
Facts
 Lino Eguia Lim Buanco executed a check for the sum of Php 2000 upon El WoN facts constitute crime of estafa
Banco Espanol Filipino without having any funds in the bank. Luciano de los YES. Defendants contend that the money was obtained with the consent of the bank
Reyes, a bookkeeper and check registry clerk of the bank, acted in conspiracy as Buanco never even made representations to El Banco Espanol Filipino. Buanco
with him by confirming the authenticity of his check with a corriente mark on the did have a transaction with Chartered Bank regarding the sum but the fact of the
check as well as manipulating the books to make it appear as if Buanco had a matter is that it was El Banco that was defrauded. The bank did not intend to allow
credit balance with the bank. Buanco to overdraw his account and it was the fraud committed that made them part
 They were convicted in the trial court of Manila with estafa. Each man requested with their money.
a separate trial and both were sentenced with 2-10-0 presidio correccional. The
decision rendering their sentences was pronounced in one joint decision. WoN this is just a case of overdraft
NO. The facts point out that the bank did not permit the overdraft. The irregularities
were carried out over months but the failure to discover the fraud does not remove
Issue criminality from the acts of the defendants.
WoN Reyes is guilty as principal in the crime of estafa
WoN crime charged in information is conspiracy, not estafa

Ratio
1. YES. Each performed the part that was necessary to enable them to accomplish
their criminal purpose. Lim Buanco represented to the bank he had credit to which he
was not entitled. Reyes falsified the accounts of Buanco to make it appear he was a
creditor (when he was in fact a debtor).
By-laws of the bank imply the directors of the bank had the duty to ascertain
the correctness of entries but that does not relieve Reyes’ acts of their criminality. The
bank was deceived by the affirmative acts of Reyes, acting in conjunction with
Buanco.

2. NO. Conspiracy is only punishable as a crime under the Penal Code when they
have certain objectives (such as treason, rebellion and plots to kill the king or his
heirs). When two people act together to perform the crime of estafa, there is no
conspiracy under the Penal Code as no penalty has been provided. No crime of
conspiracy is charged in the information. They are charged with estafa.

Ruling
Judgment of trial court AFFIRMED
 People v Maluenda (1998) inferences are derived are proven and (c) the combination of all circumstances
Respondents, Daniel Maluenda, Gil Bueno, Raul Mondaga, and Rodrigo Legarto produces a conviction beyond reasonable doubt.
Ponente, Panganiban The same circumstances also fail to prove conspiracy. Companionship and
passive presence do not prove conspiracy; that must be founded on facts. Without an
overt act showing community with the kidnappers, there is no established
Facts participation in a conspiracy.
 With Raul Mondaga as mastermind, Mondaga, Daniel Maluenda, and Rodriogo HOWEVER, Legato is not free from criminal liability as he reported the loss
Legarto were convicted by the trial court of Manila of Kidnapping. of the motorcycle when he had actually kept 36k for himself, he paid the balance of
 Mondaga, Maluenda, and a certain Alex identified themselves as Commanders the motorcycle with the 36k, and he kept possession of the motorcycle. He received
and demanded money and medicine from the Resus couple. The next day, part of the ransom and took part in the crime subsequent to its commission as he
Mondaga returned to the clinic of the Resus’ and forced Engr. Resus to come profited from it. He is liable as an accessory.
with him. He was left in a hut in Alegria with Bueno, Maluenda, and Alex.
Meanwhile, Mondaga negotiated with Dra. Resus, demanding money and the 2. YES. Maluenda is guilty as he was identified as one of the men who demanded
firearm of her husband. money and medicine from the Resus’ and he was identified as one of the guards at
 When Mondaga demanded Dra. Resus come with him, she made her helper the hut by Engr. Resus and Maria Abne. These actions show community of interest
Maria Abne go instead and also asked that Rodrigo Legarto drive for them. The with Mondaga and thus, Maluenda is guilty beyond reasonable doubt.
three returned to the hut only for Mondaga to demand that Engr. Resus put in
writing that his wife deliver 100k as ransom. As a consequence of lowering his Ruling
price, Mondaga also demanded the motorcycle of Legarto. Appeal partially GRANTED. Legarto sentence MODIFIED (2-4-1 prision correccional
 Money was exchanged with Legarto delivering the money. Of an initial 100k, an to 8-0-1 prision mayor) while Maluenda sentence AFFIRMED.
extra amount was given by Dra. Resus, some of which Legarto kept for himself.
After the exchange, Engr. and Maria Abne were released. Later on, Mondaga,
Maluenda, and Legarto were arrested.

Issue
WoN Legarto is guilty as principal by indispensable cooperation
WoN Maluenda is guilty

Ratio
1. NO. Legarto is only liable as an accessory as the evidence fails to prove him guilty
beyond reasonable doubt as principal by indispensable cooperation. No overt act was
performed on his part that showed direct participation in the kidnapping. His
participation was limited to acts after the abduction took place. He was not with the
kidnappers on the night they demanded money, when they brought the kidnap victim
to the hut, and when Mondaga demanded ransom.

There are circumstantial evidence that allegedly prove his participation.

Not appearing in court was also not proof of direct participation. Trial court
also engaged in pure speculation when they stated Legarto provided the kidnappers
with information of the Resus’ finances.
In summary, there is a lack of circumstantial evidence. To convict based on
circumstantial evidence requires (a) more than one circumstance (b) facts from which
 People v Montealegre (1988)
Respondents, Napolean Montealegre
Ponente, Cruz

Facts
 Edmund Abadilla detected the smell of marijuana from the table of Vicente
Capalad and Napolean Montealegre. He called the attention of Pfc. Renato
Camantigue who grabbed the two. Suddenly, Capalad started stabbing
Camantigue while Montealegre held Capalad and prevented him from drawing
his pistol.
 Camantigue was brought down but managed to fire at Capalad. Both died from
the wounds they sustained in the altercation. Montealegre escaped and was
eventually arrested. Trial court convicted him of complex crime of murder with
assault upon a person of authority, sentencing him to reclusion perpetua.

Issue
WoN Montealegre is guilty as principal by indispensable cooperation

Ratio
1. YES. Capalad and Montealegre collaborated to kill officer Camantigue. Capalad
stabbed him several times while Montealegre prevented him from defending himself.
Conviction as principal by indispensable cooperation requires (1) participation in the
criminal resolution and (2) cooperation in the commission of the offense by
performance of an act without which it would not have been accomplished.
(1) is fulfilled by the acts of the two as their aim was the same; to kill the
officer apprehending them. They were overt acts leading to the consummation of the
crime (People v Garcia) (2) is fulfilled as without the help of Montealegre, Camantigue
could have defended himself (People vs Labis).

Ruling
Judgment of trial court AFFIRMED

*Dicta: It should be noted Montealegre denied even knowing what was happening
during the incident. He repeatedly denied seeing anything. The Court does not
believe that as if he did run away before the stabbing, Camantigue would have been
concentrated on only one assailant. Also, the fact that Camantigue was a police
officer was known by Montealegre as he himself said so under cross-examination.
 People v Nierra (1980) Court is conviced of guilty of Nierras. They did not go to the funeral parlor to
Respondents, Paciano Nierra, Gaudencia Nierra, Felicisimo Doblen, Vicente Rojas, view the remains of Juliana. They was also a note passed to Paciano by Misa while in
Gaspar Misa the city jail, indicating that Misa would set him free if he paid Misa before the trial.
Ponente, PER CURIAM Technicality: Nierras argue that before testimony of Misa could be admitted,
the conspiracy must first be proved by evidence other than testimony. Rule 130 S27
Provisions (According to the syllabi) however only applies to extrajudicial acts or declarations, NOT testimonies (People v
Art. 18. Accomplices. — Accomplices are those persons who, not being included in Serrano).
Art. 17, cooperate in the execution of the offense by previous or simultaneous acts.
3. NO. Doblen claims that he was stranded in South Cotabato. Rojas claims he was
Republic Act No. 9372 “Human Security Act of 2007” asleep in his pumpboat. However, their actions show community of design with the
SEC. 5. Accomplice. - Any person who, not being a principal under Article 17 of the Nierras and Misa in the assassination. They are guilty as accomplices. Their
Revised Penal Code or a conspirator as defined in Section 4 hereof, cooperates in participation was not absolutely indispensable and the court should rule in favor of the
the execution of either the crime of terrorism or conspiracy to commit terrorism by milder form of liability (People v Tamayo).
previous or simultaneous acts shall suffer the penalty of from seventeen (17) years,
four months one day to twenty (20) years of imprisonment. Ruling
Judgment of trial court AFFIRMED with respect to Misa and Paciano Nierra.
Facts Gaudencia Nierra lacked the votes for the death penalty and is sentenced to reclusion
 Paciano Nierra and Juliana Nierra were competitors in launch transporation and perpetua. Doblen and Rojas are convicted as accomplices, sentenced to 10-0-0
soft drink sale. To monopolize the business, Paciano conceived the idea of prision mayor to 17-0-0 reclusion temporal.
liquidating Juliana. Felicisimo Doblen brought Gaspar Misa who agreed to kill
Juliana for 3k.
 Doblen delivered Misa a pistol and bullets. Misa asked Vicente Rojas to act as
lookout on the night of the killing. Between 7 and 8’o clock of July 8, 1969, Misa
snuck up behind Juliana while she was relieving herself on a beach and shot her
in the mouth.
 On August 7, Misa was interrogated and confessed to the crime, implicating the
other accused. On August 14, Paciano Nierra and his wife Gaudencia, Rojas,
Doblen, and Misa were charged with murder aggravated by reward, treachery,
evident premeditation, nocturnity, ignominy, and abuse of superiority.

Issue
WoN Misa is guilty
WoN Nierra spouses are guilty
WoN Doblen and Rojas are guilty as principals

Ratio
1. YES. His counsel contends that he made an improvident plea (involuntary and
without consent) as he was not informed of the gravity of the offense and the
consequences of his guilty plea. Court does not believe that as he is an escaped
prisoner with experience with criminal procedure. He executed an extrajudicial
confession twice.

2. YES. Despite attacking the credibility of Misa as a witness, Misa actually testified
against his own penal interest. His testimony that he was hired by the Nierras through
Doblen to kill Juliana and was to be paid 3k was sufficient to convict the Nierras as
inducers of the assassination. The suspected motive is the failure of the Nierras to
pay Misa the full 3k.
The Nierras also contend lack of proof of conspiracy. However, the facts
plainly show the presence of conspiracy and Misa had no motive to kill Juliana. He
was induced to do so.
 People v Doble (1982) DICTA:
Respondents, Cresencio Doble, Simeon Doble, Antonio Romaquin *Cresencio Doble and Romaquin claimed that their extrajudicial statements were
Ponente, De Castro obtained through force and intimidation. However, they were unable to present
medical certificates that attest to the injuries sustained and their five companions that
remain at large remained unidentified, suggesting a lack of coercive means being
Facts employed. Thus, their claims of torture and violence are negated.
 8 men disembarked from a banca to rob the Prudential Bank and Trust Company
in Navotas. The bank opens at midnight and closes at 8am. The band of robbers *Right to counsel was also invoked by the appellants but during their interrogation in
arrived past midnight and tried to rob the vault. Unable to open any 1966, there was no right before the 1973 Constitution.
compartments inside it, they left with 10.4k. During their escape, they engaged in
a shootout with the police that left multiple officers dead and injured. *Right against self-incrimination was also invoked to invalidate their extrajudicial
 Five of the men involved in the purportedly involved in the crime were caught. statements. However, that is immaterial as only voluntariness affects the validity of an
Two have been acquitted and three are Cresencio Doble, Simeon Doble, and extrajudicial statement.
Antonio Romaquin who have all been sentenced with the death penalty. Thus,
their cases are up for automatic review.

Issue
WoN Simeon Doble is guilty as principal
WoN Cresencio Doble and Antonio Romaquin are guilty as principals

Ratio
1. NO. Simeon Doble’s only involvement is the use of his house as the final meeting
place before the robbery. He had a five year old foot injury that made him a liability for
the robbers and thus, he was not asked to join. He did not even profit from the crime
as he received no share.

2. NO. They are liable as accomplices. Cresencio Doble’s role was only to
recommend to the robbers the banca of Antonio Romaquin as a means of transport.
He may also have, according to testimony, kept Romaquin from escaping with the
boat by keeping a gun on him. Antonio Romaquin’s role was to provide the banca.
Both knew the criminal designs of the robbers and thus, they cooperated but not in an
indispensable manner.
Romaquin also seems to have been compensated only in so far as to the
rental of his boat. He does not seem to have been given a share of the loot.
Cresencio Doble was seemingly only paid for the referral to Romaquin and thus also
has no share of the loot.
Romaquin claims his actions were not voluntary as there was the threat of
violence – the gun being kept on him to prevent his escape. However, he could have
attempted to escape but did not do so. He hid the money he received from the
robbers and repainted his boat, pointing to this guilty from his act of cooperation.
While the crimes charged include murder, the complicity of Doble and
Romaquin is limited to the robbery. The plan was to rob and that was the plan they
knew of; they were not in position to prevent the killing.

Ruling
Judgment of trial court MODIFIED. Simeon Doble is ACQUITTED. Cresencio Doble
and Antonio Romaquin are convicted as accomplices and sentenced to 5-4-21 to 8-0-
0 prision mayor.