Accused's remarks, utterances do NOT make him principal by inducement

This Court has held that for utterances of an accused to make him a principal by inducement, the same must be of such a nature and uttered in such a manner as to become the determining cause of the crime to serve such purpose, and that such inducement was uttered with the intention of producing the result (People vs. Caimbre, et al., G.R. No. L-12087, Dec. 29, 1960, People vs. Castillo, 17 SCRA 721 [1966]; People vs. Canial, 46 SCRA 634 [1972]). In other words, the inciting words must have great dominance and influence over the person who acts; they ought to be direct and as efficacious, or powerful as physical or moral coercion or violence itself. Thus, where the alleged inducement to commit the crime was no longer necessary to incite the assailant, the utterer can not be held accountable for the crime as a principal by inducement (People vs. Canial, 46 SCRA 634 [1972]; People vs. Indanan, 24 Phil. 203). In the case at bar, considering that the accused-appellant uttered the words only after the prisoners who had escaped had already beaten up and killed jail guards Basa and Valencia and seriously injured Aldana, accused-appellant's statement cannot be taken as an order to kill. It taxes the imagination how the ungrammatically translated declaration imputed to accused-appellant could become the moving cause without which the jailbreakers would not have killed or harmed the victims. The jailbreakers had already killed the guards and needed no prodding or instigation from anybody to kill. It appears, therefore, that the alleged prodding and urging were no longer necessary to induce the assailants to commit the crime. [G.R. No. 125812. November 28, 1996]