Tuesday, November 9, 2021

As an exception, however, the testimony of a co-conspirator, even if uncorroborated, will be considered sufficient if given in a straightforward manner and contains details which could not have been the result of deliberate afterthought


"Xxx.

The testimony of a co-conspirator is not sufficient for the conviction of the accused unless such testimony is supported by other evidence. As an exception, however, the testimony of a co-conspirator, even if uncorroborated, will be considered sufficient if given in a straightforward manner and contains details which could not have been the result of deliberate afterthought.[1]

Xxx.

Conspiracy was duly proven.

Like the courts below, we are equally convinced that there is sufficient evidence of conspiracy as convincing as the evidence of the participation of each of the petitioners. The records teem with circumstances correctly outlined by the trial court clearly indicating the collective and individual acts of the petitioners which reveal their common purpose to assault and liquidate the victim. For emphasis, we need to quote a portion of the ratiocination of the appellate court in this regard:

In the case at bench, as categorically attested to by witness Maramara. accused-appellants asked him to kill Pastor Papauran in exchange for money and dropping an earlier case, Criminal Case No. 24099, filed against him. They also accompanied him on the day of the shooting to see to it that the job was done. The concerted acts of accused-appellants reveal a consciously adopted plan and clearly demonstrate their joint design to exterminate Pastor Papauran. Conspiracy having been established, the act of one is the act of all.[22]

Needless to stress, these circumstances are clear enough to show that petitioners acted in concert in the implementation of a common objective - to kill the victim. In conspiracy, proof of the agreement need not rest on direct evidence. Conspiracy may be deduced from the acts of the accused before, during and after the commission of the crime which indubitably point to and are indicative of a joint purpose, concert of action and community of interest.[23] To be a conspirator, one need not participate in every detail of the execution nor talce part in every act and may not even know the exact part to be performed by the others in the execution of the conspiracy.[24] But once conspiracy is shown, as in this case, the act of one is the act of all.

Xxx."

VIRGILIO BUG-ATAN, BERME LABANDERO GREGORIO MANATAD PETITIONERS, VS. THE PEOPLE OF PHILIPPINES, Respondent. G.R. No. 175195, September 15, 2010.

https://www.chanrobles.com/cralaw/2010septemberdecisions.php?id=319