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Accomplice Liability Post-Acquittal

The Supreme Court ruled that the acquittal or dismissal of a case against alleged principals does not automatically result in the dismissal of a case against alleged accomplices. The Court affirmed that as long as the commission of a crime can be proven, the trial of those charged as accomplices can proceed independently of the principals to determine their criminal liability. In this case, the dismissal order of the alleged principals did not state that no crime was committed, so the case against the alleged accomplices for their role in a hazing incident could still be tried.

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Marion Lawrence Lara
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150 views1 page

Accomplice Liability Post-Acquittal

The Supreme Court ruled that the acquittal or dismissal of a case against alleged principals does not automatically result in the dismissal of a case against alleged accomplices. The Court affirmed that as long as the commission of a crime can be proven, the trial of those charged as accomplices can proceed independently of the principals to determine their criminal liability. In this case, the dismissal order of the alleged principals did not state that no crime was committed, so the case against the alleged accomplices for their role in a hazing incident could still be tried.

Uploaded by

Marion Lawrence Lara
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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EFFECT OF ACQUITTAL OF spite of the dismissal with finality of the case against

the principal accused. YES


PRINCIPAL TO THE
CRIMINAL LIABILITY OF RULING:
ACCOMPLICE The case against Bayabos, et al. cannot be dismissed
outright, on the sole ground that the case against the
PEOPLE VS BAYABOS, ET AL. purported principals had already been dismissed. It is
G.R. No. 171222, February 18, 2015 a settled rule that the case against those charged as
accomplices is not ipso facto dismissed in the
Digest by: Marion Lara absence of trial of the purported principals; the
dismissal of the case against the latter; or even the
latter’s acquittal, especially when the occurrence of
PRINCIPLE: the crime has in fact been established. In People v.
Rafael, the Supreme Court En Banc reasoned thus:
It is a settled rule that the case against those charged
“The corresponding responsibilities of the principal,
as accomplices is not ipso facto dismissed in the
accomplice, and accessory are distinct from each
absence of trial of the purported principals; the
other. As long as the commission of the offense can
dismissal of the case against the latter; or even the
be duly established in evidence, the determination of
latter’s acquittal, especially when the occurrence of
the liability of the accomplice or accessory can
the crime has in fact been established.
proceed independently of that of the principal.”
FACTS: Accordingly, so long as the commission of the crime
can be duly proven, the trial of those charged as
Fernando C. Balidoy, Jr. (Balidoy) was admitted as a accomplices to determine their criminal liability can
probationary midshipman at the PMMA. In order to proceed independently of that of the alleged
reach active status, all new entrants were required to principal.
successfully complete the mandatory “Indoctrination
and Orientation Period,” which was set from 2 May We note in the present case that Bayabos et
to 1 June 2001. Balidoy died on 3 May 2001. al. merely presented the Order of Entry of
Judgment dismissing the case against Alvarez et
The Assistant Provincial Prosecutor of Zambales al. Nowhere is it mentioned in the order that the case
issued a Resolution finding probable cause to charge was dismissed against the alleged principals, because
Alvarez, Montez, Reyes, and Simpas as principals to no crime had been committed. In fact, it does not cite
the crime of hazing. the trial court’s reason for dismissing the case.
The Assistant Provincial Prosecutor also endorsed to Hence, the Sandiganbayan committed an error when
the Deputy Ombudsman for the Military the finding it simply relied on the Order of Entry of Judgment
of probable cause to charge the school authorities as without so much as scrutinizing the reason for the
accomplices to hazing, including Lt. Senior Grade dismissal of the case against the purported principals.
Bayabos and others.
Meanwhile, the RTC–Zambales issued an Order
dismissing the Information against
the principal accused, Alvarez et al. The Order was
later entered in the Book of Entries of Judgment.

Bayabos, Ferrer, Magsino, Doctor, and Operio


(collectively, Bayabos et al.) filed a Motion to Quash
the Information. Bayabos et al. argued that the case
against the principal accused had already been
dismissed with finality by the RTC. There being no
more principals with whom they could have
cooperated in the execution of the offense, they
asserted that the case against them must be dismissed.
ISSUE: Whether the prosecution of Bayabos et al.
for the crime of accomplice to hazing can proceed in

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