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### Facts:
On September 16, 2007, at around 1:00 a.m., Arnel Ortigosa was stabbed leading to his death. He was with his cousin, Renato B. Flores, and Manny Boy Ditche. The group was drinking in Dupax Street, Old Balara, Quezon City. They left to buy cigarettes, encountered the accused-appellant Roberto Esperanza Jesalva alias “Robert Santos” and two others, Ryan Menieva and Junie Ilaw. Menieva stabbed Ortigosa twice with an icepick while Ilaw pointed a sumpak at the victim. Jesalva allegedly pointed toward the victim’s group. The victim was rushed to East Avenue Medical Center, where he succumbed to his injuries.
**Procedural Posture:**
1. **Filing of Information and Arraignment:**
– An Information dated March 31, 2008, was filed charging Jesalva, Menieva, and Ilaw with murder.
– Only Jesalva was arrested and pleaded not guilty; Menieva and Ilaw remained at large.
2. **Regional Trial Court (RTC) Decision:**
– Convicted Jesalva of murder, sentencing him to reclusion perpetua.
– Jesalva appealed to the Court of Appeals (CA).
3. **Court of Appeals Decision:**
– Affirmed the RTC conviction with modifications, holding that conspiracy was established.
4. **Supreme Court Appeal:**
– Jesalva appealed the CA decision. The Supreme Court found the appeal meritorious.
### Issues:
1. **Whether Jesalva conspired with Menieva and Ilaw to commit murder.**
2. **Whether Jesalva’s acts before, during, and after the incident inferred his participation in the conspiracy.**
### Court’s Decision:
**Supreme Court’s Ruling:**
1. **Lack of Conspiracy Proof:**
– Conspiracy requires conclusive proof of a common purpose to commit the crime, demonstrated by overt acts before, during, and after the felony.
– The Court found the prosecution’s evidence speculative and insufficient to prove that Jesalva conspired with his co-accused.
– The absence of any motive, pre-arranged signal, or coordination denoted that Jesalva did not have a unified criminal intent with Menieva and Ilaw.
2. **Insufficiency of Overt Acts:**
– Jesalva’s actions (leaving, returning with Menieva and Ilaw, and pointing towards the group) did not constitute participation in the stabbing nor demonstrated cooperation in its execution.
– The mere presence and seeming readiness to assist without active participation or supporting evidence do not suffice for conspiracy.
3. **No Criminal Liability without Conspiracy:**
– Without proof of conspiracy, Jesalva is only liable for his own acts.
– Jesalva’s actions, being non-criminal, did not warrant a conviction for murder.
4. **Application of Legal Standards:**
– The prosecution failed to meet the required quantum of evidence—proof beyond reasonable doubt—to establish Jesalva’s guilt.
– The Court stressed that criminal convictions must be based on moral certitude, not possibilities or conjectures.
**Result:**
– The Supreme Court reversed and set aside the decisions of the CA and RTC.
– Jesalva was acquitted of the murder charge and ordered to be immediately released unless held for another lawful reason.
### Doctrine:
1. **Essence of Conspiracy:**
– Conspiracy involves a unity of purpose and action among conspirators.
– Proof of conspiracy requires establishing common intent and agreement to commit the crime beyond reasonable doubt through overt acts.
2. **Judicial Certainty in Convictions:**
– Convictions should be based on moral certainty and clear facts, not on presumptions or weak inferences.
### Class Notes:
1. **Elements of Conspiracy:**
– (1) Agreement among conspirators.
– (2) Performance of overt acts in furtherance of the crime.
– Unity of action and purpose must be established beyond a reasonable doubt.
– **Relevant Statute:** Article 8, Revised Penal Code (RPC) of the Philippines.
2. **Principals by Indispensable Cooperation:**
– Articles 17 and 18, RPC: Principals include those who cooperate in the execution by another act without which the offense would not have been accomplished.
3. **Acquittal on Reasonable Doubt Standard:**
– The standard requires proof beyond a reasonable doubt, emphasizing the presumption of innocence until proven guilty.
### Historical Background:
– The case involves the application of conspiracy doctrines within the context of Philippine criminal law. It underscores the burden on prosecution to substantiate accusations with definite and clear proof of concerted criminal actions, reflecting principles that safeguard individual liberty and due process rights.
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