**Facts:**
On November 3, 1990, at around 11:30 PM, in Paco, Manila, a pedicab driven by Renato Garcia ran over Fernando Leaño’s foot. Incensed, Leaño chased the pedicab and exchanged invectives with Garcia, who appeared to draw a gun. Fearful, Leaño fled to his uncle, Reynaldo Bernardo’s house, and informed him. Bernardo decided they should report the incident to the police station. Bernardo, Leaño, and Arnold Corpuz headed to borrow Bernardo’s mother’s jeep. En route, they encountered Renato Garcia, Felipe Garcia, Jr. (petitioner), and Jerry Lugos, all armed. Renato shot Reynaldo Bernardo in the neck. As further gunshots followed, Leaño was fatally shot in the head. Bernardo survived due to medical intervention.
**Procedural Posture:**
– Informations were filed against Felipe Garcia Jr. for frustrated murder (Criminal Case No. 91-93374) and murder (Criminal Case 91-93375).
– The cases were consolidated.
– Upon arraignment, petitioner pleaded not guilty.
– Trial ensued, resulting in conviction: *Frustrated Homicide* and *Homicide*.
– Court of Appeals affirmed the conviction.
– Petitioner elevated to Supreme Court, raising errors primarily on the evaluation of conspiracy evidence and the facts implicating him.
**Issues:**
1. Whether the lower court erred in inferring conspiracy against Felipe Garcia, Jr. with alleged co-conspirators.
2. Whether the facts and circumstances established conspiracy sufficiently to hold petitioner liable as a co-principal.
3. Whether the petitioner should be convicted as a co-principal based merely on suspicion of conspiracy without co-conspirators being charged.
**Court’s Decision:**
1. **Conspiracy Allegation Valid:** Despite petitioner’s claim about the information being improper, the Supreme Court found a valid conspiracy charge as material facts and elements were alleged.
2. **Prima Facie Conspiracy:** The positive identification of the petitioner by witnesses and his actions, such as looking around while the crime occurred, corroborated his involvement.
3. **Accomplice, Not Principal:** Although part of the attack, Felipe Garcia, Jr.’s role was not indispensable. Hence, the Supreme Court modified his liability to that of an accomplice.
**Doctrine:**
– **Conspiracy Concept:** The act of one conspirator is the act of all. Specific actions of every conspirator need not be detailed in the information if conspiracy is alleged.
– **Accomplice Liability:** A person aiding the principal act with knowledge and purpose may be liable as an accomplice if their involvement is neither direct nor indispensable.
**Class Notes:**
– **Elements of Conspiracy:** Agreeing to commit a crime, acting together towards the crime.
– **Accomplice vs. Principal:** Knowledge of the crime and aiding its commission without being indispensable.
– **Revised Penal Code References:**
– **Art. 8:** Defines conspiracy.
– **Art. 18:** Defines accomplice participation.
**Historical Background:**
The decision reflects the nuances in proving conspiracy and differentiating roles in criminal participation within Philippine jurisprudence. This case underscores the principle that substantial participation, though indirect, invokes liability but invites a measured approach in establishing the degree of culpability in complex criminal actions.
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