7.

PEOPLE OF THE PHILIPPINES vs. EDGARDO LIAD and JUN VALDERAMA

335 SCRA 11, March 22, 2001, 1st Div., Kapunan, J.

FACTS:
On February 28, 1996, at around 7:00 pm, Liad and Valderama, wilfully and unlawfully assault
Lydia Dy-Cuenca. The accused pursuant to their conspiracy, flagged down the victims vehicle.
However, when the latter refused to open her car, they fired two successive shots at the
windshield, hitting the victim, which was the cause of her death. After that, the accused boarded
the same vehicle but abandoned it later upon robbing money and valuable items belonging to the
victim. As soon as the police were informed about the incident, they went to the compound
where the perpetrators were said to be sited. There, they had an encounter with the latter.
Besides robbery with homicide, accused-appellants were also charged with illegal possession of
firearm. Upon arraignment, they pleaded not guilty and offered denial as their defense.

ISSUES:
1. Whether or not conspiracy exists in the commission of the crime
2. Whether or not the accused-appellants should be convicted of robbery with homicide
3. Whether or not they are guilty of illegal possession of firearms

HELD:
The Court finds that the prosecution established beyond reasonable doubt the existence of
conspiracy. In this case, there were several circumstances immediately before, during and after
the robbery which show that the perpetrators were one in their purpose to rob the victim.
Moreover, SC held that the accused-appellants are guilty of robbery with homicide. Whenever
homicide has been committed as a consequence or on the occasion of the robbery, all those who

took part as principals in the robbery will also be held guilty as principals for the special
complex crime of robbery with homicide, although they did not actually take part in the
homicide.
Regarding illegal possession of firearm, accused-appellants were acquitted for insufficiency of
evidence. The prosecution failed to prove that the paltik, a homemade gun, should have
corresponding license or permit to possess.