CASE DIGEST: People v. Jaime Jose, G.R. No. L-28232

Title: People v. Jaime Jose, G.R. No. L-28232

Subject Matter: Conspiracy

Facts:

On June 26, 1967, four principal-accused Jaime Jose, Basilio Pineda Jr., Eduardo Aquino and Rogelio Cañal conspired together, confederated with and mutually helped one another, then and there, to willfully, unlawfully and feloniously, with lewd design to forcibly abduct Magdalena “Maggie” dela Riva, 25 years old and single, a movie actress by profession at the time of the incident, where the four principal accused, by means of force and intimidation using a deadly weapon, have carnal knowledge of the complainant against her will, and brought her to the Swanky Hotel in Pasay City, and hence committed the crime of Forcible Abduction with Rape.

Having established the element of conspiracy, the trial court finds the accused guilty beyond reasonable doubt of the crime of forcible abduction with rape and sentences each of them to the death penalty.

Issue:

Whether or not the trial court made a proper ruling of the case considering the element of conspiracy.

Held:

No, the trial court’s ruling was not proper. The SC ruled that since the element of conspiracy was present, where the act of one is the act of all, each of the accused is also liable for the crime committed by each of the other persons who conspired to commit the crime. The SC modified the judgment as follows: appellants Jaime Jose, Basilio Pineda Jr., and Eduardo Aquino are guilty of the complex crime of forcible abduction with rape and each and every one of them is likewise convicted of three (3) other crimes of rape. As a consequence thereof, each of them is likewise convicted with four death penalties and to indemnify the victim of the sum of P10,000 in each of the four crimes. The case against Rogelio Cañal was dismissed only in so far as the criminal liability is concerned due to his death in prison prior to promulgation of judgment.