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ART. 17. PRINCIPALS- Principal by Direct Participation- Revised Penal Code

 

ART. 17. PRINCIPALS

I. There are three kinds of principals depending on the nature of their participation in the commission of the crime. However, irrespective of what type of principal they belong, their penalty will be the same. They are the following:

A. Principal by Direct Participation

B. Principal by Indespensable Cooperation

C. Principal by Inducement

A. BY DIRECT PARTICIPATION (PDP)

A. This refers to those who actually and directly take part in the execution of the act. In all crimes there must always be those who actually perform the act which brings about the crime. They may be only one person or more. Whenever there are two or more involved in a crime, it becomes necessary to find out those who actually executed the act so that all may be held equally liable.

B. To hold two or more persons as principals by direct participation, it must be shown that there exists a conspiracy between and among them. This is not the conspiracy punished as a crime but the conspiracy as a mode or manner of incurring criminally or that legal relationship whereby, in the eyes of the law, it may be said that the act of any one is the act of all.

II. For conspiracy to exist, there be an intentional felony, not a culpable felony, and it must be proved that all those to be considered as PDPs performed the following:

A. ( Unity of Intention) They participated, agreed, or concurred in the criminal design, intent or purposes or resolution.

1. This participation may be prior to the actual execution of the acts which produced the crime ( Anterior Conspiracy )  or it may be at the very moment the acts are actually being executed and carried out ( Instant Conspiracy).

2. Hence it is not necessary to prove that before the commission of the crime, the several accused actually came and met together to plan or discuss the commission of the crime.

3. “Spontaneous agreement or active cooperation by all perpetrators at the moment of the commission of the crime is sufficient to create a joint criminal responsibility” ( Sim Jr. vs. CA, 428 SCRA 459)

B. (Unity of Action ). All participated in the execution or carrying out of the common intent, design, purpose or objective by acts intended to bring about the common objective.

1. Each must have performed an act, no matter how small or insignificant so long as it was intended to contribute to the realization of the crime conspired upon.  This requires that the principal by direct participation must be at the crime scene, except in the following instances:

a). When he is the mastermind

b). When he orchestrates or directs the actions of the others from some other place

c). His participation or contribution was already accomplished prior to the actual carrying out of the crime conspired such: his role was to conduct surveillance or to obtain data or information about the place or the victims; to purchase the tools or weapons, or the get away vehicle, or to find a safe house

d). His role/participation is to be executed simultaneously but elsewhere, such as by crating a diversion or in setting up a blocking force

e). His role/participation is after the execution of the main acts such as guarding the victim; looking for a buyer of the loot; “laundering” the proceeds of the crime

III. Participation in both ( Intention and Action) is necessary because:

A. Mere knowledge, acquiescence or agreement to cooperate, is not enough to constitute one as a party to a conspiracy, absent any active participation in the commission of the crime, with a view to the furtherance of the criminal design and purpose. Conspiracy transcends companionship

B. He who commits the same or similar acts on the victim but is a stranger to the conspiracy is separately liable. Simultaneous acts by several persons do not automatically give rise to conspiracy.

C. Examples:

1. X joined in the planning of the crime but was unable to join his companions on the day of the crime because he was hospitalized. He is not liable.

2. X is the common enemy of A and B who are strangers to one another. Both A and B chanced upon X.  A stabbed X while B shot him. A and B will have individual liabilities.

D. Exception: When a person joins a conspiracy after its formation, he thereby adopts the previous acts of the conspirators which are admissible against him. This is under the Principle of Conspiracy by Adoption.

IV. Proof of Conspiracy

 

A. Direct proof of conspiracy is not necessary. The existence thereof maybe inferred under the Doctrine of Implied Conspiracy which directs that if two or more persons:

(i). Aimed by their acts towards the accomplishment of the same unlawful object

(ii). Each doing a part so that their acts, though apparently independent, were in fact connected and cooperative

(iii). Indicating a closeness of personal association and a concurrence of sentiment

(iv).A conspiracy maybe inferred though no actual meeting among them to concert is proved.

V. Effect of Conspiracy. There will be a joint or common or collective criminal liability, otherwise each will be liable only to the extent of the act done by him.

VI. For what crime will the co-conspirators be liable?

A. For the crime actually committed if it was the crime agreed upon

B. For any other crime even if not agreed upon, provided it was the direct, natural, logical consequence of, or related to, or was necessary to effect, the crime agreed upon. Otherwise only the person who committed the different crime will be held liable.

VII. When is a co-conspirator freed from liability?

A. Only if he has performed an overt act either to:

1. Disassociate or detach himself from the plan

2. Prevent the commission of the second or different or related crime  

B. Likewise, if for any reason not attributable to the law enforcement agents, he was not able to proceed to the crime scene and/or execute an act to help realize the common objective, then he can not be held liable as a co-conspirator. Thus he is not liable if he got sick, overslept, or forgot about it, but not when law agents took him into custody to prevent him from doing his part of the agreement.

Thus in Robbery with Homicide, all who conspired in the robbery will be liable for the homicide unless one of the conspirators proved he tried to prevent the homicide.

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