33. People v.

Valdez
159 SCRA 153/25 March 1988
Accused: Danilo Valdez and Simplicio Orodio
Decision by J. Feliciano, Digest by Roe Anuncio

Short Version: Valdez and Orodio were charged with and convicted by the trial court of murder,
thereby being sentenced to death. On automatic review, the SC discussed the argument of the OSG that
the guilt of Orodio was not proven beyond reasonable doubt by the prosecution because conspiracy was
not sufficiently proven, it only having been alleged that he was seen running away with Valdez after the
gunshot. SC confirms the guilt of Orodio, taking into account all the circumstances enumerated below.

Facts: Eleno Maquiling was having dinner with his family at their house when he was shot to death.
Witnesses thereafter saw Valdez and Orodio running away from the bushes outside the house, Valdez
carrying a shotgun. Valdez and Orodio were charged with and convicted by the trial court of murder for
the shooting of Eleno, thereby being sentenced to death. The case was brought to the SC for automatic
review. The Court discussed the argument put forward by the OSG that accused-appellant Simplicio
Orodio should be acquitted for lack of sufficient evidence to sustain this conviction either as a principal or
an accomplice. According to the OSG, the prosecution did not adduce any evidence establishing the
aforesaid alleged conspiracy between Valdez and Orodio to commit the crime charged.

Issue: Was there conspiracy? YES.

Ruling: RTC decision affirmed.

Ratio: Circumstances evidencing conspiracy: 1) Orodio was present with Valdez at the time Eleno
Maquiling was killed; 2) he was in the company of a man running with a shotgun, at approximately 8:00
o'clock in the evening, immediately after the fatal shooting, just outside the Maquilings house where he
had no business being if he were not acting in concert with Danilo Valdez; 3) he was a close friend
(barkada) of the accused Danilo Valdez, both of whom the deceased victim had Identified as probably
responsible should any untoward event befall the victim; 4) Orodio completely failed to explain what he
was doing with Danilo Valdez the night of the killing; 5) both Danilo Valdez and Simplicio Orodio pleaded
the same alibi. Their common alibi remained uncorroborated. The prosecution had adequately proven the
conspiracy.

Both Danilo Valdez and Simplicio Orodio are liable as co-conspirators since any act of a co- conspirator
becomes the act of the other regardless of the precise degree of participation in the act.