Case of People of the R.P. vs.

Pugay
No. L-74324 17November1988
FACTS OF THE CASE:
The accused are pronounced by the RTC of Cavite guilty beyond reasonable doubt for the crime of murder of Bayani Miranda and sentencing them
to a prison term ranging from 12 years (prison mayor) as mimimum to 20 years (prison temporal) as maximum and for samson to be sentenced to
reclusion perpetua.
Miranda and the accused Pugay are friends. Miranda used to run errands for Pugay and they used to sleep together. On the evening of May 19, 1982
a town fiesta was held in the public plaza of Rosario Cavite. Sometime after midnight accused Pugay and Samson with several companions arrived
(they were drunk), and they started making fun of Bayani Miranda. Pugay after making fun of the Bayani, took a can of gasoline and poured its
contents on the latter, Gabion (principal witness) told Pugay not to do the deed. Then Samson set Miranda on fire making a human torch out of him.
They were arrested the same night and barely a few hours after the incident gave their written statements.
ISSUES OF THE CASE:
Is conspiracy present in this case to ensure that murder can be the crime? If not what are the criminal responsibilities of the accused?
There is no:
CONSPIRACY- is determined when two or more persons agree to commit a felony and decide to commit it. Conspiracy must be proven with the
same quantum of evidence as the felony itself, more specifically by proof beyond reasonable doubt. It is not essential that there be proof as to the
existence of a previous agreement to commit a crime. It is sufficient if, at the time of commission of the crime, the accused had the same purpose
and were united in its executed.
Since there was no animosity between miranda and the accused, and add to the that that the meeting at the scene of the incident was purely
coincidental, and the main intent of the accused is to make fun of miranda.
Since there is no conspiracy that was proven, the respective criminal responsibility of Pugay and Samson arising from different acts directed against
miranda is individual NOT collective and each of them is liable only for the act that was committed by him.
**Conspiracy may be implied from concerted action of the assailants in confronting the victim.
Criminal Responsibilities:
PUGAY: Having failed to exercise diligence necessary to avoid every undesirable consequence arising from any act committed by his companions
who at the same time were making fun of the deceased. - GUILTY OF RECKLESS IMPRUDENCE RESULTING TO HOMICIDE
SAMSON:Since there are NO sufficient evidence that appears in the record establishing qualifying circumstances (treachery, conspiracy). And
granted the mitigating circumstance that he never INTENDED to commit so grave a wrong. - GUILTY OF HOMICIDE
HELD:
JUDGEMENT OF THE LOWER COURT WAS AFFIRMED WITH MODIFICATIONS. JUDGEMENT FOR GUILTY BEYOND REASONABLE DOUBT FOR MURDER WAS
LOWERED TO THE ABOVE JUDGEMENTS.
I hope this helps.