Chua v.
People
FALLO: WHEREFORE, the Court DENIES the petition for review on certiorari; AFFIRMS in all
respects the decision promulgated on Octobe 20, 2005, subject to the following
MODIFICATIONS, to wit:
(1) Petitioner CELERINO CHUA ALIAS SUNTAY is punished in Criminal Case No. 397-M-94, for
carnapping, with the indeterminate sentence of 18 years, as minimum, to 22 years, as
maximum; and
(2) The actual damages of P200,000.00 shall earn legal interest of 6% per annum reckoned
from the finality of this decision until full satisfaction.
The petitioner shall pay the costs of suit.
FACTS:
At around 2:50 o'clock in the morning, Teresa Legaspi-Ravago, accompanied by a
helper, was about to leave for work at the Maymart Market in Meycauayan, Bulacan.
Upon opening the door, she was immediately pushed inside the house by accused
Arnold Lato. Lato was followed by accused Leonardo Reyes.
Arnold tied the hands of Teresa and the helper with straw. Leonardo on the other hand
went to the master's bedroom where Reynaldo was sleeping, who was stabbed four
times but was able to run to the bathroom and lock himself in.
Accused demanded jewelry and cash that the Ravagos earned as broker's commission
from the sale of a fishpond.
The two robbers wore stockings on the head to conceal their identities. Teresa was
able to recognize the face of Arnold when the latter removed the stocking off his face
as he searched for jewelry.
Said two (2) accused carted off their television sets, Sony Betamax sets, Karaoke,
compact disc, assorted pieces of jewelry, VHS player and cash. The said stolen items
were loaded in a stainless owner type jeep registered in the name of Teresa's mother.
The stolen jeep was later found in a motor shop in Bani, Pangasinan, where Chua had
been sold it for P40,000.00
Chua was identified as the mastermind behind the crimes, having referred the co-
accused to their employer and having sold the stolen jeep.
Reyes and Lato remained at large; hence, only Chua was arraigned and tried for the
crimes.
Chua was convicted by the RTC of Malolos, Bulacan, for carnapping and robbery, which
was affirmed by the CA.
Chua appealed to the Supreme Court, arguing that the circumstantial evidence was
insufficient to establish his guilt beyond reasonable doubt.
ISSUE/S: WON there is an existence of a conspiracy among the accused.
RULING: YES, there is a conspiracy among the accused.
The Supreme Court upheld the decision of the CA, affirming Chua's conviction for both
robbery and carnapping. The Court found that the circumstantial evidence presented was
sufficient to establish Chua's guilt beyond reasonable doubt.
Despite not physically being present during the crimes, Chua was held liable as a principal by
inducement.
Being the mastermind, Chua was as responsible for the consequences of the acts committed
by Lato and Reyes, the principals by direct participation. This is because of the conspiracy
among the three of them. The informations had properly charged them as co-conspirators in
robbery and carnapping. Once their conspiracy was established, the act of each of the
conspirators became the act of all. Indeed, Chua could not escape responsibility for the acts
done by his co-conspirators. The very nature of the planned robbery as a crime that entailed
violence against persons warranted holding Chua fully responsible for all the consequences
of the criminal plot.
Direct evidence was not the sole means of establishing the guilt of the accused beyond
reasonable doubt. The lack or absence of direct evidence putting the accused at or near the
scene of robbery and carnapping at the time of their commission did not necessarily mean
that his guilt could not be proved by evidence other than direct evidence. Conviction could
also rest purely on circumstantial evidence, which is that evidence that proves a fact or series
of facts from which the fact in issue may be established by inference. Circumstantial
evidence, if sufficient, could supplant the lack or absence of direct evidence. It may be
resorted to when to insist on direct testimony would ultimately lead to setting felons free.
Section 4, Rule 133 of the Rules of Court provides when circumstantial evidence is sufficient
for conviction if the conditions enumerated therein are shown to exist, to wit:
Section 4. Circumstantial evidence, when sufficient. - Circumstantial evidence is sufficient for
conviction if:
(a) There is more than one circumstance;
(b) The facts from which the inferences are derived are proven; and
(c) The combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt.
The foregoing circumstances were sufficient and competent to prove that Chua
masterminded the robbery and carnapping. As the mastermind, he directly induced Lato and
Reyes to commit the robbery and the carnapping. His inducement of them was not merely
casual but influential and controlling. Lato and Reyes could not have committed the crimes
without Chua's inducement and plotting. In that capacity, Chua was a principal by
inducement within the context of Article 17 of the Revised Penal Code, which provides:
Article 17. Principals. - The following are considered principals:
1. Those who take a direct part in the execution of the act;
2. Those who directly force or induce others to commit it;
3. Those who cooperate in the commission of the offense by another act without which it
would not have been accomplished.
Conspiracy exists when two or more persons come to an agreement concerning the
commission of a crime, and decide to commit it. For an accused to be validly held to conspire
with his co-accused in committing the crimes, his overt acts must tend to execute the offense
agreed upon, for the merely passive conspirator cannot be held to be still part of the
conspiracy without such overt acts, unless such passive conspirator is the mastermind. In that
respect, it is not always required to establish that two or more persons met and explicitly
entered into the agreement to commit the crime by laying down the details of how their
unlawful scheme or objective would be carried out. Conspiracy can also be deduced from the
mode and manner in which the offense is perpetrated, or can be inferred from the acts of
the several accused evincing their joint or common purpose and design, concerted action and
community of interest. Clearly, the State successfully proved the existence of a conspiracy
among the three accused.
