Criminal Law 1

Topic: Conspiracy and Porposal

Case: ROSIE QUIDET, Petitioner,vs.PEOPLE OF THE PHILIPPINES, Respondent.

G.R. No. 170289 | April 8, 2010
Digested by: Rizzie P. Soliman

Recit-Ready Doctrine (Simplified Take Away):

The case involves Rosie Quidet and his co-accused, Feliciano Taban, Jr., and Aurelio Tubo, who were
charged with homicide and frustrated homicide for an incident that occurred on October 19, 1991, in
Barangay Looc, Salay, Misamis Oriental, Philippines. The prosecution alleged that the accused, with the
intent to kill, conspired to attack Jimmy Tagarda and his cousin, Andrew Tagarda, using sharp-pointed
instruments, which resulted in Jimmy's death and Andrew's injuries.

During the trial, the defense argued that there was no pre-existing grudge or motive for the attack and
that the incident arose from an accidental encounter between the two groups. Taban entered a guilty
plea in Criminal Case No. 92-079, while Rosie Quidet and Tubo maintained their innocence.

The trial court found the accused guilty of homicide and frustrated homicide, ruling that conspiracy was
established based on the coordinated actions of the accused. The Court of Appeals affirmed the
convictions with modifications, reclassifying the offense in Criminal Case No. 92-080 as attempted
homicide and deleting some of the awarded damages.

The central issue in the case was whether conspiracy was proven beyond a reasonable doubt,
particularly concerning Rosie Quidet's involvement, and whether the convictions for homicide and
attempted homicide were justified based on the evidence presented during the trial.

Facts:

● Rosie Quidet, Feliciano Taban, Jr., and Aurelio Tubo were charged with homicide in Criminal Case
No. 92-079 for the death of Jimmy Tagarda and frustrated homicide in Criminal Case No. 92-080
for the injuries sustained by Jimmy's cousin, Andrew Tagarda.
● The incidents occurred on October 19, 1991, in Barangay Looc, Salay, Misamis Oriental,
Philippines.
● The prosecution's version of events alleged that the accused, with intent to kill, conspired to
attack Jimmy and Andrew using sharp-pointed instruments, resulting in Jimmy's death and
Andrew's injuries.
● The defense argued that the accused did not have a grudge against the victims and that the
incident arose from an accidental encounter between the two groups.
● Petitioner Rosie Quidet maintained his innocence, while Taban entered a guilty plea in Criminal
Case No. 92-079.
 ● The trial court found the accused guilty of homicide and frustrated homicide, ruling that
conspiracy was established due to the concerted acts of the accused.
● The Court of Appeals affirmed with modifications, reclassifying the offense in Criminal Case No.
92-080 as attempted homicide and deleting some of the awarded damages.

Issue:

The main issue in the case revolves around the determination of whether conspiracy was sufficiently
established beyond reasonable doubt. Specifically, it questions whether Rosie Quidet conspired with the
other accused (Taban and Tubo) in the commission of the offenses charged, and if the convictions for
homicide and attempted homicide were proper in light of the evidence presented during the trial.

Ruling:

Trial Court's Verdict:

● The trial court convicted Rosie Quidet and Aurelio Tubo of homicide and the three accused of
attempted homicide.
● It sentenced Taban to imprisonment and ordered him to pay ₱50,000 as civil indemnity for the
homicide charge.
● The trial court sentenced all three accused to an indeterminate sentence for attempted
homicide and ordered them to pay ₱10,000 to the victim's heirs.

Court of Appeals' Decision:

The Court of Appeals affirmed the trial court's judgment but modified the charge of attempted homicide
to attempted homicide, and deleted the ₱10,000 award to the heirs of Andrew Tagarda.
Issues and Arguments:

Rosie Quidet appealed the decision, arguing that conspiracy was not established beyond reasonable
doubt, and that his participation was limited to punching the victims after the stabbings had occurred.

Supreme Court's Ruling:

● The Supreme Court agreed with the appellant, Rosie Quidet, that conspiracy had not been
proven beyond reasonable doubt.
● The Court emphasized that conspiracy requires conclusive proof and cannot be inferred solely
from joint and simultaneous actions.
● The Court noted inconsistencies in the prosecution witnesses' testimonies regarding the
sequence of events and the defendants' actions.
● It highlighted that there was no evidence of a motive for the accused to harm the victims.
● Since conspiracy was not proven, each defendant's liability was separate and individual.
● Rosie Quidet was found guilty of slight physical injuries and was sentenced to 15 days of arresto
menor.
 ● Taban and Tubo were found guilty of attempted homicide and were sentenced to a shorter
prison term.
● The Court ordered the accused to pay damages to the victims' heirs but modified the amounts
based on the charges and evidence presented.
● The Court also acknowledged that preventive imprisonment should be credited to the accused
according to law.

Conclusion:
The Supreme Court partially granted the appeal, ruling that conspiracy was not proven beyond
reasonable doubt, and individual liabilities should be assessed. It modified the charges and damages
accordingly.