Confederation, NOT aggravating

Confederation is not enumerated as an aggravating circumstance under Article 14 of the Revised Penal Code. Like conspiracy which must be alleged in and not merely inferred from the information, confederation is but a mode of incurring criminal liability and may not be considered criminal in itself unless specifically provided by law. Neither may confederation be treated as an aggravating circumstance in the absence of any law defining or classifying it as such. (People vs. Baroy, G.R. Nos. 137520-22, 09 May 2002, 382 SCRA 56)