PEOPLE V.

PARUNGAO
FACTS:
 The case is about the detention prisoners in Pampanga Provincial Jail in San Fernando who staged a jailbreak,
killing jail guards Basa and Valencia, and wounding jail guard Aldana charging 15 prisoners and the accused-
appellant Abelardo Parungao, with the crime of Robbery with Homicide and serious physical injuries. A
separate trial convicted 4 of the accused and acquitted 2 of them.
 According to the prosecution,witness Quito a prisoner, testified that in the Provincial Jail of San Fernando
Pampanga, he was asked by his cell mates Solis and Pabalan if he wanted to join them in a jailbreak, to which
he answered “bahala na”
o They told him there would be no problem as many prisoners will join, and that Abelardo Parungao
was the mastermind
 Thereafter Sevilla, a detainee handed a letter to Pabalan, which instructs them to tie Jail Guard Basa and put
off the main switch
 Sevilla opened cell no 2, releasing the prisoners including Quito
 While in the jail yard, Quito saw Parungao shouting to Sevilla to open their cell. However when it was not
opened, Parungao and his cell mates did not go out
 The prisoners who were freed passed by four jail guards who were sleeping, Basa, Valencia, Aldana and
Pacheco
o And to ensure their escape, they tied the guards, beat them with bamboo sticks and stabbed them
with knives, killing Basa and Valencia, wounding Aldana, and leaving Pacheco unharmed
 Parungao who was in his cell was heard by Pacheco shouting “Alright go ahead and kill those son of a bitch”,
to the prisoners beating up the jail guards
 Later, the Integrated National Police of San Fernando, Pampanga showed that 6 firearms were missing from
the prison armory
 Parungao puts up a defense of denial.
o He claimed that during the jailbreak he was inside his cell with the rest of his cellmates
o A brownout occurred and he lay on the floor upon hearing gunshots
o He said he had nothing to do with the jailbreak and was implicated because the prosecution
witnesses, jail guards and prisoners took offense against him because he had reported them for drug
trafficking inside the jail
 The Regional Trial Court of San Fernando, Pampanga gave credit to the prosecution’s evidence, and finds
Parungao guilty sentencing him to suffer the penalty of life imprisonment
 Hence the appeal by the accused on the decision
o Contending that the RTC erred in accepting and giving probative value to the hearsay testimony of the
prosecution witnesses, finding him a co-conspirator and a principal by inducement
ISSUE:
 Whether or not the accused-appellant is a co-conspirator and a principal by inducement
RATIO:
 No, the Supreme Court cannot agree with the trial court’s decision.
 As was stated by the prosecution witness Pacheco, the accused-appellant shouted words of encouragement
to one of the prisoners; however these remarks or utterances do not make him a principal by inducement.
 According to the Supreme Court, for such utterances to make an accused a principal by inducement, it must
be of such a nature and uttered in such a manner to become the determining cause of the crime.
 The words must have great dominance and influence over the person who acts; they must be direct,
powerful, moral ascendancy or violence itself.
 Thus if the alleged inducement was not necessary to incite the assailants, the utterer is not to be held liable as
a principal by inducement.
 In the case at bar, considering the accused-appellant uttered the words only after the escaped prisoners have
beaten up and killed the 2 jail guards and injured one, his utterances are not considered as an order to kill.
 The prisoners have already done the act, and need not the prodding or instigation from anybody to kill.
 The proddings and urgings were not anymore necessary to induce the assailants to commit the crime.
 The SUPREME COURT REVERSED the RTC decision, and ACQUITTED Abelardo Parungao.
PEOPLE V. FRONDA

Facts:
Brothers, Edwin & Esminio Balaan
were taken by 7 armed men in fatigue
uniforms with long firearms,
suspected to be NPA members,
accompanied by the accused Rudy
Fronda and Roderick Padua from the
house of Ferminio Balaan. The armed
men tied the hands of the deceased at
their back lying down face
downward, in front of the house of
Ferminio. They all proceeded towards
Sitio Tulong passing through
the rice fields. Three years later, the
bodies or remains of the Balaan brothers
were exhumed.
Afterwhich, the remains, were brought
to the house of Freddie Arevalo, a
reltive of the deceased where
they were laid in state for the wake. The
RTC declared Fronda guilty as a
principal by indispensable
cooperation. The appellant says he was
only taken by the armed men as a
pointer & interposes the
exempting circumstance under RPC
A12(6) claiming that all his acts were
performed under the impulse
of uncontrollable fear and to save his
life.
Issue: Whether or not Fronda can claim
the exempting circumstance of
uncontrollable fear.
Held: No. Fear in order to be valid
should be based on a real, imminent or
reasonable fear for one’s life
or limb. (People vs. Abanes) In the case
at bar, the records indicate that appellant
was seen being
handed by and receiving from one of the
armed men a hunting knife. Also, as
aforesaid, appellant was
not able to explain his failure to report
the incident to the authorities for more
than three years. These
circumstances, among others, establish
the fact that the appellant consciously
concurred with the acts
of the assailants. In order that the
circumstance of uncontrollable fear may
apply, it is necessary that the
compulsion be of such a character as to
leave no opportunity to escape or self-
defense in equal combat.
(People v. Loreno) Appellant had the
opportunity to escape when he was
ordered by the armed men to
go home after bringing the victims to the
mountains. He did not. Instead he joined
the armed men when
required to bring a spade with which he
was ordered to dig the grave. Appellant
also chose to remain
silent for more than three years before
reporting the killing to the authorities.
Based on these
circumstances, We hold that the
contemporaneous and subsequent acts of
appellant cannot be
regarded as having been done under the
impulse of uncontrollable fear.
Facts:
Brothers, Edwin & Esminio Balaan
were taken by 7 armed men in fatigue
uniforms with long firearms,
suspected to be NPA members,
accompanied by the accused Rudy
Fronda and Roderick Padua from the
house of Ferminio Balaan. The armed
men tied the hands of the deceased at
their back lying down face
downward, in front of the house of
Ferminio. They all proceeded towards
Sitio Tulong passing through
the rice fields. Three years later, the
bodies or remains of the Balaan brothers
were exhumed.
Afterwhich, the remains, were brought
to the house of Freddie Arevalo, a
reltive of the deceased where
they were laid in state for the wake. The
RTC declared Fronda guilty as a
principal by indispensable
cooperation. The appellant says he was
only taken by the armed men as a
pointer & interposes the
exempting circumstance under RPC
A12(6) claiming that all his acts were
performed under the impulse
of uncontrollable fear and to save his
life.
Issue: Whether or not Fronda can claim
the exempting circumstance of
uncontrollable fear.
Held: No. Fear in order to be valid
should be based on a real, imminent or
reasonable fear for one’s life
or limb. (People vs. Abanes) In the case
at bar, the records indicate that appellant
was seen being
handed by and receiving from one of the
armed men a hunting knife. Also, as
aforesaid, appellant was
not able to explain his failure to report
the incident to the authorities for more
than three years. These
circumstances, among others, establish
the fact that the appellant consciously
concurred with the acts
of the assailants. In order that the
circumstance of uncontrollable fear may
apply, it is necessary that the
compulsion be of such a character as to
leave no opportunity to escape or self-
defense in equal combat.
(People v. Loreno) Appellant had the
opportunity to escape when he was
ordered by the armed men to
go home after bringing the victims to the
mountains. He did not. Instead he joined
the armed men when
required to bring a spade with which he
was ordered to dig the grave. Appellant
also chose to remain
silent for more than three years before
reporting the killing to the authorities.
Based on these
circumstances, We hold that the
contemporaneous and subsequent acts of
appellant cannot be
regarded as having been done under the
impulse of uncontrollable fear.
FACTS:
 Brothers Edwin & Esminio Balaan were taken by 7 armed men in fatigue uniforms with long firearms,
suspected to be NPA members, accompanied by the accused Rudy Fronda and Roderick Padua, from the
house of Ferminio Balaan in a Barangay in Cagayan.
o Fronda and Padua were residents of the same place.
 The armed men tied their hands at their back lying down face downward, in front of the house of Ferminio.
They proceeded towards Sitio,Tulong passing through the rice fields, taking the 2 brothers.
 According to Fronda, he was taken by the NPAs from his house to look for the brothers where they tied their
hands and brought them to the mountains.
 He was instructed to go home, but in the same day, the NPAs recalled him and ordered him to get a spade and
a crowbar where they dug a hole in the mountain.
 Three years later, the remains of the brothers were exhumed, brought to the house of Freddie Arevalo, a
relative of the deceased where they were laid in state for the wake.
 The defense submits that Fronda was only taken by the armed men as a pointer & interposes an exempting
circumstance, claiming that all his acts were performed under the impulse of uncontrollable fear and to save
his life.
 The RTC of Aparri, Cagayan after enumerating established facts:
o Fronda and Padua pointed the house of the brothers
o Accompanied the members of the armed group and tied the victim’s hands
o Fronda was handed a hunting knife when they left the house
o Accused joined the armed group in bringing the victims to a forested area in the mountains
o Fronda provided the spade and crowbar used in digging the hole where the victims were buried
o Fronda failed to report the incident for a period of more than 3 years
o The appellant did not in any way object when he was ordered to tie the hands of the victims
o declared Fronda guilty as a principal by indispensable cooperation for the crime of MURDER
sentencing him to reclusion perpetua in both cases.

ISSUES:
 Whether or not Fronda should be convicted as a principal by indispensible cooperation
 Whether or not Fronda should be convicted as an accomplice

HELD:
----------------------------------------------------INDISPENSIBLE COOPERATOR------------------------------------------------------
 The court ruled in the negative. The participation of Fronda in the commission of the crime is: 1) leading the
armed men to the house of the brothers, 2) tying the victims’ hands and 3) digging the grave where they were
buried.
 The testimony of a former member of the NPA discloses that Fronda was only picked up by the armed men for
the purpose of pointing the residence of the victims.
 The armed men didn’t disclose to Fronda their purpose for looking for the victims who were former AFP
members nor did they inform him of their plan to abduct and kill him
 The prosecution witness also established that even without the participation of Fronda, the armed men will
be able to find the brothers thru Padua, being a resident of the place
 To be a principal by indispensible cooperation, there must be a direct participation in the criminal design by
another act without which the crime could not have been committed.
 The prosecution failed to present any evidence to establish the appellant’s conspiracy with the evil designs of
the members of the NPA armed group. Neither was it established that his act was of such importance that the
crime would not have been committed without him or that he participated in the actual killing.
 Under such circumstances, he cannot be considered a principal by indispensible cooperation.
------------------------------------------------------------ACCOMPLICE-----------------------------------------------------------------------
 Fronda is guilty for being an accomplice, because of his acts of joining the armed men and failing to object to
their unlawful orders.
o This can be considered as his concurrence with the objectives of the malefactors and also giving them
material aid in the commission.
 He cannot claim that he was unaware of such evil intentions by the armed men.
o In fact, it was he who tied the arms of the victims, joined the men in bringing them to the hills and
failed to report the incident for three years.
 An accomplice is one who, not being a principal “cooperates in the execution of the offense by previous or
simultaneous acts”. A person is considered an accomplice if his role in the perpetration of the crime is of a
minor character.
 It is necessary that he be aware of the criminal intent of the principal and cooperates intentionally, supplying
material aid for the efficacious execution of the crime.
 If there is ample evidence of criminal participation but a doubt exists as to the nature of liability, the courts
should resolve to favor the milder form of responsibility, that of an accomplice.
----------------------------------------------------UNCONTROLLABLE FEAR----------------------------------------------------------------
 Appellant cannot claim the exempting circumstance of uncontrollable fear. In order for fear to be valid, it
should be based on a real, imminent or reasonable fear for one’s life or limb.
 In the case at bar, records indicate that appellant was seen being handed by the armed men a hunting knife.
 Also he was unable to explain his failure to report the incident for 3 years.
 In order that uncontrollable fear may apply, it is necessary that the compulsion be of such a character as to
leave no opportunity to escape or self-defense in equal combat. He had the opportunity to escape when he
was ordered to go home.

 The SUPREME COURT MODIFIED the decision of the RTC finding him guilty as an accomplice in the crime of
murder.
People v De Vera
Facts:
About 1:30 in the afternoon of June 8, 1992, while bringing out the garbage, the witness, Bernardino Cacao
saw a car passing by, driven by victim Frederick Capulong together with four (4) other passengers(Edwin de Vera,
Roderick Garcia “Deo”, Kenneth Florendo and Elmer Castro) . He knew the victim by name who was a resident of
the subdivision. He recognized and identified two of the passengers as Kenneth Florendo and Roderick Garcia, both
familiar in the subdivision. "Cacao did not at first notice anything unusual inside the car while it passed by him, but then
he heard unintelligible voices coming from the car as it was cruising around Denver Loop Street, a circular road whose
entrance and exit were through the samepoint. His curiosity taking the better part of him, Cacao walked to the opposite
side of the road from where he saw the car already parked. Moments later, he saw the victim dragged out of
the car by Florendo and brought to a grassy place. Florendo was holding a gun. Upon reaching the grassy spot,
Florendo aimed and fired the gun at the victim, hitting him between the eyes. After the shooting, Florendo and his
companions fled in different directions.Cacao identified Garcia and pointed to appellant as amongthe companions
of Florendo.Frederick Capulong suffered from 5 caliber shots in between his eyes and was stroke with the use of a
baseball bat in the mouthwhich lead to his immediate death. The security guard reported the incident to the police and
the policemen went around the subdivision to look for possible suspects. They came upon a person wearing muddied
maongpants and white t-shirt `standing and walking around' near the clubhouse of the subdivision. When asked
his name, the person identified himself as Edwin de Vera, herein appellant. Suspicious of his conduct, the policemen
brought appellantto Station 5 and turned him over to the desk officer for investigation. Florendo and Garcia had guns,
and Castro had a baseball bat. Appellant claims that he had no part in the killing, and that it was Kenneth
Florendo who had shot the victim. Moreover according to him,he heard the voices of Kenneth and his friend and they
appeared to be arguing. The voices came from some twenty-two (22) meters away. Not before long, Edwin also heard a
gunshot which came from where Kenneth and Elmer had gone to. He was shocked because he was not used to hearing
gunfire. Frightened, he panicked and ran away from the place. His singular thought while running was to get out of
Filinvest. Trial Court of Quezon City found Appellant Edwin De Vera and Accused Roderick Garcia guilty beyond
reasonable doubt of murder and sentencing them to reclusion perpetua, whilethe other two accused were at large.

Issue: Whether or not the appellant is deemed to be an accomplice or a conspirator?

Held: Appellant should be convicted only as an accomplice, not as a principal.Appellant's presence was not
innocuous. Knowing that Florendo intended to kill the victim and that the three co-accused were carrying weapons, he
had acted as a lookout to watch for passersby. He was not an innocent spectator; he was at the locus criminisin order to
aid and abet the commission of the crime. These facts, however, did not make him a conspirator; at most, he was only
an accomplice.The Revised Penal Code provides that a conspiracy exists when "two or more persons come to an
agreement concerning the commission of a felony and decide to commit it."[17] To prove conspiracy, the
prosecution must establish the following three requisites: "(1) that two or more persons came to an agreement,
(2) that the agreement concerned the commission of a crime, and (3) that the execution of the felony [was]
decided upon."[18] Except in the case of the mastermindof a crime, it must also be shown that the accused
performed an overt act in furtherance of the conspiracy.[19] The Court has held that in most instances, direct proof of
a previous agreement need not be established, for conspiracy may be deduced from theacts of the accused pointing to a
joint purpose, concerted action and community of interest.[20] On the other hand, the Revised Penal Code defines
accomplices as "those persons who, not being included in Article 17,[21] cooperatein the execution of the offense
by previous or simultaneous acts."[22] The Court has held that an accomplice is "one who knows the criminal design of
the principal and cooperates knowingly or intentionally therewith by an act which, even if not rendered, the crime
would be committed just the same." To hold a person liable as an accomplice, two elements must be present: (1) the
"community of criminal design; that is, knowing the criminal design of the principal by direct participation, he
concurs with the latter in his purpose;" and(2) the performance of previous or simultaneous acts that are not
indispensable to the commission of the crime.Conspirators and accomplices have one thing in common: they know
and agree with the criminal design. Conspirators, however, know the criminal intention because they themselves
have decided upon such course of action. Accomplices come to know about it afterthe principals have reached the
decision, and only then do they agree to cooperate in its execution. Conspirators decide that a crime shouldbe
committed; accomplices merely concur in it. Accomplices do not decide whether the crime should be
committed; they merely assent to the plan and
cooperate in its accomplishment. Conspirators are the authors of a crime; accomplices are merely their
instruments who perform acts not essential to the perpetration of the offense.In the present case, Appellant De
Vera knew that Kenneth Florendo had intended to kill Capulong at the time, and he cooperated with the latter.
But he himself did not participate in the decision to kill Capulong; that decision was made by Florendo and the others.
He joined them that afternoon after the decision to kill had already been agreed upon; he was there because
"nagkahiyaan na." "[L]ack of complete evidence of conspiracy, that creates the doubt whether they had acted as
principals or accomplices in theperpetration of the offense, impels this Court to resolve in their favor the question, by
holding x x x that they were guilty of the `milder form of responsibility,' i.e., guilty as mere accomplices."WHEREFORE,
the appeal waspartially GRANTED. Appellant De Vera wass CONVICTED as an accomplice, not as a principal, in the crime
of murder
PEOPLE V. LORENO
FACTS:
 Elias Monge was at his house along with his daughters Monica (14), Cristina (22, married), wife Beata,
sons Mario (11) and Nilo (13), Cristina’s daughter Rachel (4 mos.) and farm helper Francisco Fabie.
 While Francisco was at the balcony, he saw at first four men with flashlights approaching, where one of them
called Elias saying there is a letter from the chief.
 2 men, one with a dark sweater and one with red clothes came up the house.
 Elias, who went out to the balcony where the man in dark sweater handed him the letter and because it was too
dark for the letter to be read, Elias invited the man inside the sala. The man in red clothes positioned himself
near the post of the balcony.
 Elias instructed her daughter to get his reading glasses, only to find out the content that the men were members
of NPA.
 The man in dark sweater ordered them not to make any ruckus and pointed a gun to Elias.
 The same man ordered everyone inside to lie on the floor.
 Meanwhile, the man in red clothes, who stayed with Francisco in the balcony, asked for a glass of water.
 Francisco himself went inside to get a glass, only to be followed by the man in red clothes, who later on pointed
a gun and a knife at him. Francisco, together with Monica and Cristina recognized the man as Eustaqio Loreno.
 The man in dark sweater instructed Loreno to tie all their victims on the floor with their hands behind their
backs and ordered Loreno to drive a barking dog away.
 Francisco was brought by Loreno outside, and there he saw one of the lookouts to be Jimmy Marantal
 The man in dark sweater then got a hold of Monica and dragged her to a room where she was asked where her
piggy bank is. When she said there was none, he forcibly removed her pants. She screamed for help to her
parents and despite the struggle, he successfully had sex with her.
 The parents heard her screaming but Loreno pointed his gun and told them not to rise if they want to live.
 Loreno brought Beata to different rooms and proceeded to take its contents.
 After this, he dragged Monica back to the sala and proceeded to do the same to Cristina.
 A third man also entered the sala, who was seen to be taking rice. Also a fourth man entered the sala, and boxed
Elias. The third and fourth men were also not identified.
 Thereafter, Loreno entered the room where Cristina was lying on the floor and proceeded to kiss and touch her.
Suddenly, one of the men outside called and told everyone to hurry up because someone was approaching the
house.
 The malefactors left taking the valuables and warned them not to tell anyone.
 They managed to untie themselves eventually and after positively affirming the identities of their
malefactors, along with Elias finding out the sexual abuse his daughters suffered, filed a report against the
robbery-rape incident.
 Loreno and Marantal were detained and charged with the crime of Robbery with Double Rape the other
malefactors being at large (6).
 The accused claimed they were acting under the impulse of uncontrollable fear as they were forced by the man
in black sweater with his 5 companions that their families would be killed.
 The Court of First Instance of Camarines Sur found Loreno guilty of the crime charged sentenced to suffer life
imprisonment, and Marantal guilty of robbery sentenced to suffer indeterminate penalty of prision
coreccional to prision mayor.
 Hence the appeal from the decision of the CFI.
ISSUES
 Whether or not the accused Jimmy Marantal being only a lookout is a co-principal
HELD:
 Yes. Marantal, being a lookout or a guard outside the house of the victims is considered a co-principal as he
gave his companions effective means and encouragement to carry out and commit the crimes of robbery and
rape.
 There has been no showing that he raised a voice of protest or did an act to prevent the commission of the
crimes, and that him being a lookout is a necessary part of the concerted acts to achieve the result.
 Based on the evidence, conspiracy was clearly established as it can be inferred and proven by the acts of the
accused, Loreno and the others ransacking the house, tying the victims and raping the 2 girls.
 All these demonstrated the voluntary participation and conspiracy of the appellants. Although it is separately
performed, it clearly showed the concert of criminal design without need of direct proof of conspiracy itself.
 Conspiracy being established, the conspirators are liable as co-principals regardless of their participation.
 The SUPREME COURT AFFIRMED the DECISION of the lower court, with MODIFICATIONS that JIMMY should
suffer the penalty of reclusion perpetua.
PEOPLE V. BOCO
FACTS:
 The case is about the accused Carlos Boco and Ronaldo Inocentes, who were charged with violation of Section
21, Article 4 of the Dangerous Drugs Law(RA 6425 as amended), after a buy bust operation in Mandaluyong
City, to which they pleaded not guilty.
 According to the prosecution, in October 1996, a confidential informer arrived in District Anti-Narcotic Unit,
Eastern Police District in Pasig City and talked with Captain Bonifacio
o Cpt. Bonifacio told SPO1 Magallanes that the informer would come back and if the suspect is
available, he would act as a poseur buyer
o A team was formed to effect a buy bust operation when the informer had returned
 The team together with the informer and SPO1 Magallanes proceeded to a Brgy. In Mandaluyong City, being
the pre-arranged meeting place, where the members placed themselves in strategic areas
 A while later a Mitsubishi Lancer arrived where the informer and SPO1 Magallanes was
o On the vehicle were 2 men, and the informer introduced Magallanes to Boco at the passenger’s seat
 After a short conversation, SPO1 Magallanes asked if he had the previously ordered shabu. He answered in
the affirmative and told him it would cost him P20, 000.
o SPO1 Magallanes showed the money, but asked to examine the shabu before he will give it to him
o His companion Inocentes took a heat sealed plastic from the glove compartment gave it to Boco and
then to Magallanes, examining it and positively identified it as shabu
 SPO1 Magallanes made the pre-arranged signal to his back up, and arrested the suspects after introducing
themselves as policemen.
 5 pieces of plastic bags taped around the leg were recovered from Boco and 1 from Inocentes
 They were informed of the offense they had committed, informed of their constitutional rights and brought
over the police headquarters where the suspected shabu were verified.
 The accused maintained a defense of denial and alibi.
o According to them they picked up Boco’s live in partner and when they were about to leave, men
approached their vehicle, drew their guns and ordered them to alight, and board a van to bring them
to the Eastern Police District
o While on a stop in 7/11 in Mandaluyong, Captain Bonifacio arrived and told them “Yari kayo shabu
was found on your car”
o They were brought to the Eastern Police District and required to face press people and deny the
charges
o They were transferred to the City Jail of Mandaluyong City
 The Regional Trial Court of Pasig City rendered a decision, giving more weight to the evidence of prosecution,
finding the accused guilty beyond reasonable doubt and to suffer the EXTREME PENALTY of DEATH.
 Hence the appeal on the decision of the RTC.
ISSUES:
 Whether or not the trial court erred in not ruling that the prosecution failed to identify the shabu which
constitutes the corpus delicti of the offense
HELD:
 The court ruled in the negative.
 Material to a prosecution for illegal sale of dangerous drugs is the proof that the transaction or sale actually
took place, coupled with the presentation in court of the corpus delicti as evidence.
 Corpus delicti has 2 elements: proof of occurrence of the certain event (for example that a man has died or a
building has been burned) and some person’s criminal responsibility for the act.
 The principal witnesses to the commission of the offense for which the appellants are accused clearly
established the elements which are: an illegal sale of the regulated drug actually took place and the accused
were the authors thereof.
 Also there are no material inconsistencies between the testimonies of the principal witnesses, and in fact,
they complement each other in giving a complete picture as regard the illegal sale of the regulated drug.
 However the trial court erred in imposing the death penalty to the accused.
 In accordance with Article 63(no. 2) of the RPC the lesser penalty is applied when there is neither mitigating nor
aggravating circumstance in the commission of the offense. The PROPER PENALTY IS RECLUSION PERPETUA.
 OTHER ISSUES:
 FRAME UP- IT IS NOT A FRAME UP BECAUSE THE ACCUSED-APPELLANTS FAILED TO PROVE BY SUFFICIENT
EVIDENCE TO SUBSTANTIATE THEIR CLAIMS. THEY SUBMITTED NO PLAUSIBLE REASON OR ILL MOTIVE ON THE
PART OF THE ARRESTING OFFICERS THAT WOULD LEAD TO THEIR ALLEGATION OF FRAME UP OR EXTORTION.
 CONSPIRACY – CONSPIRACY WAS OUTRIGHT ESTABLISHED. CONSPIRACY NEED NO DIRECT PROOF TO BE
ESTABLISHED, AS IT CAN BE SEEN AND INFERRED FROM THE ACTS OF THE ACCUSED BEFORE, DURING AND
AFTER THE COMMISSION OF THE OFFENSE, POINTING TO A JOINT PURPOSE OR CONCERT OF ACTION. IN THE
CASE AT BAR, THE FACT THAT THE ACCUSED ARRIVED ON BOARD THE SAME VEHICLE, BOCO TALKED TO THE
OFFICER, AND INNOCENTES TAKING OUT THE SAMPLE SHABU CONSTITUTES A JOINT PURPOSE- TO SELL SHABU.