People vs Gambao

Facts:
Lucia Chan was kidnapped by the appellants. Levy Chan, the son of Lucia, was able to report the
incident. The police were able to formulate a plan to rescue Lucia. They were able to intercept the van
carrying the ransom money as well as Karim, Abao, Gambao, and Dukilman. The police also assaulted
the resort cottage where Lucia was detained. Dilangalen, Udal, Macalinbol, Mandao, Perpenian, Evad,
and Ronas were apprehended during the assault. The appellants were convicted of Kidnapping for
Ransom. They decided to appeal to the Court of Appeal and the court affirmed the decision with
modifications. The Supreme Court required the parties to file their supplemental briefs. In their briefs,
Dukilman, Ronas, and Evad argued that their conspiracy was not convincingly established. Dukilman
argued that he was not one of those arrested during the rescue operation. Ronas and Evad argued that
they had no participation in the negotiation for the ransom money.
Issue: Whether or not the appellants conspiracy was convincingly established.
Held:
Although Dukilman was not apprehended during the rescue operation, it was sufficiently established
that he was one of those apprehended during the interception of the van carrying the ransom money.
Ronas and Evad were also arrested during the rescue operation. The Court has held before there is no
need to participate in every detail of the execution to be a conspirator. There is no need to take part in
every act or even know the part to be performed by others in the execution of the conspiracy. Once
conspiracy is shown, the act of one is the act of all the conspirators. The precise extent or modality of
participation of each of them becomes secondary, since all the conspirators are principals. Moreover,
Chan positively identified the accused-appellants and placed all of them at the crime scenes. With the
conspiracy among the appellants established beyond reasonable doubt, the act of one is the act of all
conspirators.