SC requires conspiracy to be proved BEYOND reasonable doubt

Conspiracy has not been established beyond reasonable doubt. It is a rule that although there is no direct evidence of prior agreement to commit the crime, conspiracy may be inferred from the acts of the accused before, during, and after the crime which are indicative of a joint purpose, concerted action, and concurrence of sentiments (People vs. de Leon, et al., 245 SCRA 538 [1995]). The record is bereft of any evidence indicating a prior plan or agreement between accused-appellant and the other inmates in the implementation of a common design to bolt jail, kill the guards, and rob the prison armory. There is no evidence that accused-appellant participated in the killing of the two guards, Basa and Valencia, nor in inflicting injuries on Aldana. In fact, accused-appellant before, during, and after the incident never left his cell. [G.R. No. 125812. November 28, 1996]

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