People vs De Vera, G.R. No.
128966, August 18, 1999 "community" of criminal design; that is, knowing the criminal
Facts: The accused and his co-accused, Garcia, was charged with murder for
the death of Frederick Capulong. A witness alleged that the two accused was
seen inside the car of the victim and two other men shot the victim. Capulong
was killed by a gun shot. Later, the accused was arrested by policemen and
the other accused was apprehended by a security guard, however the others
were able to escape. On trial, the accused admitted of having knowledge of
the plan after the other accused decided on killing the victim and that when
the crime was committed, he was unarmed. The RTC finds the existence of
conspiracy and held the accused guilty as a principal.
Issue: Whether or not the accused should be held as principal.
Held: No, the accused should not be held as principal but as an accomplice.
The SC ruled that an accomplice is "one who knows the criminal design of the
principal and cooperates knowingly or intentionally therewith by an act
which, even if not rendered, the crime would be committed just the same."
Here, knowing that Florendo intended to kill the victim and that the three co-
accused were carrying weapons, he had acted as a lookout to watch for
passersby. He was not an innocent spectator; he was at the locus criminis in
order to aid and abet the commission of the crime. These facts, however, did
not make him a conspirator; at most, he was only an accomplice.
Notes:
Conspiracy exists when "two or more persons come to an
Padiernos, et. al. vs People, G.R. No. 181111, August 17, 2015
agreement concerning the commission of a felony and decide to
commit it." To prove conspiracy, the prosecution must establish the
following three requisites: "(1) that two or more persons came
to an agreement, (2) that the agreement concerned the
commission of a crime, and (3) that the execution of the felony
[was] decided upon." Except in the case of the mastermind of a
crime, it must also be shown that the accused performed an overt act
in furtherance of the conspiracy.
Accomplices as "those persons who, not being included in Article
17, cooperate in the execution of the offense by previous or
simultaneous acts." An accomplice is "one who knows the criminal
design of the principal and cooperates knowingly or intentionally
therewith by an act which, even if not rendered, the crime would be
committed just the same." Two elements must be present: (1) the
design of the principal by direct participation, he concurs with
the latter in his purpose;" and (2) the performance of previous
or simultaneous acts that are not indispensable to the
commission of the crime.
Conspirators and accomplices have one thing in common: they know
and agree with the criminal design.
Distinction:
Conspirators, however, know the criminal intention because they
themselves have decided upon such course of action. Accomplices
come to know about it after the principals have reached the decision,
and only then do they agree to cooperate in its execution.
Conspirators decide that a crime should be committed; accomplices
merely concur in it. Accomplices do not decide whether the crime
should be committed; they merely assent to the plan and cooperate
in its accomplishment. Conspirators are the authors of a crime;
accomplices are merely their instruments who perform acts not
essential to the perpetration of the offense.
Once conspiracy is proven, the liability is collective and not
individual. The act of one of them is deemed the act of all. In the case
of an accomplice, the liability is one degree lower than that of a
principal.
Facts: Padiernos et. al., were charged as accessories to the crime of illegal
possession of lumber, in violation of PD No. 705 or the Forestry Reform Code
of the Philippines. According to the Information, the petitioners took away
the truck that carried the lumber to prevent its use as evidence and to avoid
its confiscation and forfeiture. The defense argued that they could not be held
liable as accessories because the authorities had already discovered the
crime and had control over the truck when the petitioners drove it. The
prosecution maintains that the petitioners' acts were aimed at preventing the
discovery of the crime. The RTC convicted petitioners Padiernos et. al. as
accessories to the crime of violation of P.D. 705. The RTC found that the
petitioners' testimonies and admissions established their prior knowledge
that the truck had been previously confiscated for illegal transport of forest
products. On appeal, the CA affirmed the conviction.
 Issue: Whether or not the accused should be held as accessories to the crime.
Held: No. the accused should not be held as accessories to the crime. The SC
ruled that the facts alleged in the Information and the crime proved in the
present case do not make the petitioners liable as accessories for violation of
P.D. 705. They are, however, liable for violation of Section 1(b) of P.D. 1829.,
Under par 2 of Article 19 of the RPC defines "accessories" as those who, with
knowledge of the commission of the crime and without having participated
therein, either as principals or accomplices, take part subsequent to its
commission by concealing or destroying the body of the crime, its
effects or instruments, in order to prevent its discovery.
Under this provision, the punished acts should have been committed
for the purpose of preventing the discovery of the crime. In the present
case, the crime punishable under P.D. 705 - the illegal possession of
lumber - had already been discovered at the time the petitioners took the
truck.
The factual allegations in the Information, while not constituting an
offense committed by accessories under Article 19, paragraph 2 of the RPC,
constitute instead the criminal offense of obstruction of justice.
P.D. 1829 addresses the necessity of penalizing acts which obstruct or
frustrate or tend to obstruct or frustrate the successful apprehension
and prosecution of criminal offenders.
People vs. Henry T. Go, G.R. No. 168539, March 25, 2014
Facts: The accused, Henry T. Go, is a private individual. He was charged with
violation of R.A. 3019, otherwise known as the Anti-Graft and Corrupt
Practices Act. It was alleged that he conspired with then DOTC Secretary
Arturo Enrile in entering into a contract which is grossly and manifestly
disadvantageous to the government. However, the said public was not
indicted because he died prior to the issuance of the resolution finding
probable cause. The SB gave the prosecution to show cause why this case
should not be dismissed for lack of jurisdiction over the person of the accused
considering that the accused is a private person and the public official Arturo
Enrile, his alleged co-conspirator, is already deceased, and not an accused in
this case. The defense filed a motion to quash the information before the SB
and was subsequently granted.
Issue: Whether or not the accused can still be indicted for conspiracy even if
the public officer, with whom he was alleged to have conspired, has died
prior to the filing of the Information.
Held: Yes, the accused can still be indicted for conspiracy even if the public
officer, with whom he was alleged to have conspired, has died prior to the
filing of the Information. The SC ruled that it is not necessary to join all
alleged co-conspirators in an indictment for conspiracy. If two or more
persons enter into a conspiracy, any act done by any of them pursuant to the
agreement is, in contemplation of law, the act of each of them and they are
jointly responsible therefor. This means that everything said, written or
done by any of the conspirators in execution or furtherance of the
common purpose is deemed to have been said, done, or written by each
of them and it makes no difference whether the actual actor is alive or
dead, sane or insane at the time of trial. The death of one of two or more
conspirators does not prevent the conviction of the survivor or
survivors.
Sharica Mari L. Go-Tan vs Spouses Perfecto and Juanita Tan, G.R. No. 168852,
September 30, 2008
Facts: The petitioner, Sharica Mari L. Go-Tan, filed a petition for protective
order against her husband, Steven, and her parents-in-law, Spouses Perfecto
and Juanita Tan a violation of RA No. 9262, otherwise known as the "Anti-
Violence Against Women and Their Children Act of 2004. She alleged that all
the accused conspired with one another in the commission of the said
violation. The parents-in-law filed a Motion to Dismiss contending that the
RTC lacked jurisdiction over their persons since, as parents-in-law of the
petitioner, they were not covered by R.A. No. 9262. The RTC dismissed the
case on that ground The RTC reasoned that to include respondents under the
coverage of R.A. No. 9262 would be a strained interpretation of the
provisions of the law.
Issue: Whether or not the parents-in-law can be included in the petition.
Held: Yes, the parents-in-law can be included in the petition. The SC ruled
that, R.A. No. 9262 expressly provides for the suppletory application of the
RPC. Thus, the Penal Code may be applied in a supplementary capacity to
crimes punished under special laws, such as R.A. No. 9262, in which the
special law is silent on a particular matter. the principle of conspiracy under
Article 8 of the RPC may be applied suppletorily to R.A. No. 9262 because of
the express provision of Section 47 that the RPC shall be supplementary to
said law. Thus, general provisions of the RPC, which by their nature, are
necessarily applicable, may be applied suppletorily.
People vs Marlon Lambert De Leon, G.R. No. 179943, June 26, 2009
Facts: The accused, Marlon Lambert De Leon was charged with the crime of
robbery with homicide. It was alleged that the accused together with other
men announced a hold – up in gasoline station. All men are armed with
weapons. Witnesses saw the accused poked a gun to one of the victims. As a
result of the robbery, one victim died due to gunshot wound by one of the
other accused. The accused were arrested by the police. On his defense, he
alleged that he was not one with the robber and was also a victim. The RTC,
finds the accused to be in conspiracy with the others and was convicted with
the crime charged.
Issue: Whether or not the accused can be held liable to the crime charged as a
co-conspirator.
Held: Yes, the accused can be held liable to the crime charged as a co-
conspirator. The SC ruled that if it is proved that two or more persons
aimed by their acts towards the accomplishment of the same unlawful
object, each doing a part so that their combined acts, though apparently
independent, were in fact connected and cooperative, indicating a
closeness of personal association and a concurrence of sentiment, a
conspiracy may be inferred though no actual meeting among them to
concert means is proved. That would be termed an implied conspiracy.
The prosecution was able to prove the presence of an implied conspiracy. it
can be inferred from the role appellant played in the commission of the
robbery, that a conspiracy existed and he was part of it. To be a conspirator,
one need not participate in every detail of the execution; he need not
even take part in every act or need not even know the exact part to be
performed by the others in the execution of the conspiracy.
Notes:
When homicide is committed by reason or on the occasion of
robbery, all those who took part as principals in the robbery would
also be held liable as principals of the single and indivisible felony of
robbery with homicide, although they did not actually take part in
the killing, unless it clearly appears that they endeavored to prevent
the same.
If a robber tries to prevent the commission of homicide after the
commission of the robbery, he is guilty only of robbery and not of
robbery with homicide. All those who conspire to commit robbery
with homicide are guilty as principals of such crime, although not all
profited and gained from the robbery. One who joins a criminal
conspiracy adopts the criminal designs of his co-conspirators and
can no longer repudiate the conspiracy once it has materialized.
People vs Roberto Esperanza, G.R. No. 227306, June 19, 2017
Facts: The accused, Roberto Esperanza, was charged the crime of murder. It
was alleged that before the killing of the victim happened, the accused can be
seen to be staring at the group of the victim then walked-away and
disappeared. Later, accused reappeared, accompanied by his group and that
the accused pointed at the group while the victim was stabbed by a member
of his group. The RTC finds the accused conspired with his group in the killing
of the victim and the same was affirmed by the CA.
Issue: Whether or not the accused should be held liable in conspiracy in the
commission of the crime charged.
Held: No, the accused should not be held liable in conspiracy in the
commission of the crime charged. The SC ruled that conspiracy must be
established beyond reasonable doubt. Accused's act of pointing to the victim
and his group is not an overt act which shows that accused acted in concert
with his co-accused to cause the death of the victim. Mere knowledge,
acquiescence or approval of the act, without the cooperation and the
agreement to cooperate, is not enough to establish conspiracy. Even if
the accused were present and agreed to cooperate with the main
perpetrators of the crime, their mere presence does not make them
parties to it, absent any active participation in the furtherance of the
common design or purpose. Likewise, where the only act attributable to
the other accused is an apparent readiness to provide assistance, but
with no certainty as to its ripening into an overt act, there is no
conspiracy. In this case, while accused-appellant's presence and act of
pointing at the victim and his group may mean he approved of the crime or
that he was ready to assist his co-accused, absent any other overt act on his
part, there is no conspiracy.
Caoili vs CA, G.R. No. 128369, December 22, 1997
Facts: The accused Caoili together with Tony Yip was charged with violation
of PD 1612. The accused sought a review by the Secretary of Justice which
renders a resolution in his favor. The Secretary of Justice directed the
exclusion of Caoili from the information. However, the RTC refused to exclude
Caoili and the CA finds no grave abuse of discretion to such refusal.
 Issue: Whether or not Caoili should be excluded from the information.
Held: No, Caoili should not be excluded from the information. The SC rule
that, the opinion of the secretary of justice that the accused do not indicate
that Caoili acquired the skiving machines in question knowing that the same
were stolen property. That the prima facie presumption of fencing from
possession of stolen property does not apply to Caoili as complainant
reacquired the subject skiving machines not from respondent Caoili but from
Yip. Further, it is simply contrary to common human behavior that a person
would intimate to another or others an unlawful act, that he purchased stolen
items and then dispose of it at a profit. And that evidence to be believed must
not only proceed from the mouth of a credible witness but it must be credible
in itself such as the common experience and observation of mankind can
approve as probable under the circumstances. However, the rule in this
jurisdiction is that once a complaint or information is filed in Court any
disposition of the case as [to] its dismissal or the conviction or acquittal of the
accused rests in the sound discretion of the court.
Cahulogan vs People, G.R. No. 225695, March 21, 2018
Facts: It was alleged that private complainant, Johnson Tan, instructed his
truck driver and helper to deliver 210 cases of Coca-Cola products to Demins
Store for value. The next day he found out that the products were delivered to
the accused. Tan went to the accused and demanded the return of the
product but the accused refused, claiming that he bought the same from his
driver. Tan tried to negotiate but failed. He charged the accused with the
crime of fencing. The RTC convicted the accused. On appeal, the CA affirmed
the conviction.
Issue: Whether or not the accused committed the crime of fencing.
Held: Yes, the accused committed the crime of fencing. The SC ruled that the
essential elements of the crime of fencing are as follows: (a) a crime of
robbery or theft has been committed; (b) the accused, who is not a
principal or an accomplice in the commission of the crime of robbery or
theft, buys, receives, possesses, keeps, acquires, conceals, sells or
disposes, or buys and sells, or in any manner deals in any article, item,
object or anything of value, which has been derived from the proceeds
of the crime of robbery or theft; (c) the accused knew or should have
known that the said article, item, object or anything of value has been
derived from the proceeds of the crime of robbery or theft; and (d)
there is, on the part of one accused, intent to gain for oneself or for
another. Fencing is a malum prohibitum, and PD 1612 creates a prima
facie presumption of Fencing from evidence of possession by the accused
of any good, article, item, object or anything of value, which has been the
subject of robbery or theft; and prescribes a higher penalty based on the
value of the property. In this case, all the elements of the crime of Fencingare
present: (a) Lariosa sold to petitioner the subject items without authority and
consent from his employer, Tan, for his own personal gain, and abusing the
trust and confidence reposed upon him as a truck helper; (b) petitioner
bought the subject items from Lariosa and was in possession of the same; (c)
under the circumstances, petitioner should have been forewarned that the
subject items came from an illegal source, as his transaction with Lariosa did
not have any accompanying delivery and official receipts, and that the latter
did not demand that such items be replaced with empty bottles, contrary to
common practice among dealers of soft drinks; 28 and (d) petitioner's intent to
gain was made evident by the fact that he bought the subject items for just
P50,000.00, lower than their value in the amount of P52,476.00.
Francisco vs People, G.R. No. 146584, July 12, 2004
Facts: Pacita is a household helper in the residence of Jovita. It was alleged
that Pacita asked Macario to sell some jewelries of her friend. The accused,
Ernesto Francisco, is the owner of a shop that buys gold. He had several
transactions involving the said jewelries with Macario, brother of Pacita.
Jovita noticed that several of her jewelries are missing and suspected Pacita
as the one who stole the same. A complaint was filed against Pacita and she
was arrested. In her statement admitted thecommission and led the police to
the store of Francisco. Francisco was chaged with violation of PD 1612. The
RTC finds the accused guilty of the violation of PD No. 1612. On appeal the CA
affirmed the decision of the RTC.
Issue: Whether or not the accused can be held liable of the crime charged.
Held: No, the accused can be held liable of the crime charged. The SC ruled
that the knowledge that the jewelry was stolen, the prosecution is burdened
to prove facts and circumstances from which it can be concluded that the
accused should have known that the property sold to him were stolen. This
requirement serves two basic purposes: (a) to prove one of the elements of
the crime of fencing; and, (b) to enable the trial court to determine the
imposable penalty for the crime, since the penalty depends on the value of
the property; otherwise, the court will fix the value of the property
Enrile vs Judge Amin, G.R. No. 93335 September 13, 1990
 Facts: An information charged Senator Juan Ponce Enrile as having
committed rebellion complexed with murder and another information
charging him for violation of Presidential Decree No. 1829 were filed. It was
alleged that Senator Enrile harbored or concealed Ex. Lt. Col. Gregorio
"Gringo" Honasan. The defense contends that the pending charge of rebellion
complexed with murder and frustrated murder against Senator Enrile as
alleged co-conspirator of Col. Honasan, preclude the prosecution of the
Senator for harboring or concealing the Colonel on the same occasion under
PD 1829. Respondent Judge Amin sustained the charge of violation of PD No.
1829 notwithstanding the rebellion case filed against the petitioner on the
theory that the former involves a special law while the latter is based on the
Revised Penal Code or a general law.
Issue: Whether or not the rebellion case filed against Senator Enrile
precludes the filing of violation of PD No. 1829.
Held: Yes, the rebellion case filed against Senator Enrile precludes the filing of
violation of PD No. 1829. The SC ruled that as decided in the case of People v.
Hernandez prohibit the complexing of rebellion with any other offense
committed on the occasion thereof, either as a means to its commission or as an
unintended effect of an activity that commutes rebellion. The crime of rebellion
consists of many acts. It is described as a vast movement of men and a
complex net of intrigues and plots. Jurisprudence tells us that acts committed
in furtherance of the rebellion though crimes in themselves are deemed
absorbed in the one single crime of rebellion. In this case, the act of harboring
or concealing Col. Honasan is clearly a mere component or ingredient of
rebellion or an act done in furtherance of the rebellion. It cannot therefore be
made the basis of a separate charge.
Posadas vs Ombudsman, Gr. 131492, September 29, 2000
 
Facts: There was a rumble between 2 fraternities in UP Diliman which
resulted to the death of Dennis Venturina. Posadas, the Chancellor of UP
Diliman, sought the assistance of NBI. On the basis of positive identification
by alleged 2 witnesses, the NBI officers attempted to arrest the 2 members of
Scintilla Juris Fraternity. Posadas and 2 other members of UP and the counsel
of suspects objected to such arrest on the ground that the NBI did not have a
warrant of arrest. Posadas and others promised to surrender the suspects the
following day. However, they failed to do so, because the said 2 suspects
escaped. An information against the 2 suspects were filed and another
information against Posadas et. al. was filed charging them with violation of
P.D. 1829 for preventing the NBI to make the arrest which led to the escaping
of the suspects. The Office of the Ombudsman directed the Special Prosecutor
to proceed with the prosecution in the Sandiganbayan. 
 
Issue: Whether or not there was a probable cause for prosecuting Posadas et.
al. for violation of PD 1829.
 
Held: No, there was no probable cause for prosecuting Posadas et. al. for
violation of PD 1829. The SC ruled that, probable cause is defined as
"sufficient ground to engender a well-founded belief that a crime cognizable
by the court has been committed and that the respondents are probably
guilty thereof and should be held for trial" (Sec1, Rule 12, Rules of Court). The
absence of an arrest warrant, the absence of knowledge or reasonable ground
on the part of the accused to believe that the students had committed a crime,
the absence of any law punishing refusal to attend an investigation at the NBI,
all show that there is no sufficient ground to charge the accused with
Obstruction of Justice. On the contrary, the circumstances show that the
accused, in safeguarding the rights of students, were acting within the bounds
of law.
 
Judge Angeles vs Judge Gaite, G.R. No. 165276, November 25, 2009
 
Facts: The petitioner, Judge Angeles, was the foster mother of 14 years old
Maria Mercedes Vistan. The petitioner extended her support not only to
Maria but also to her siblings, including Michael Vistan, a half-brother of
Maria. One evening, Michael and Judge Angeles had an argument which led to
the petitioner’s remarked that she will stop supporting the family of Michael.
It was alleged that Michael conspired with others and was able to induced
Maria to leave the custody of the petitioner. After knowing what happened
and failure to locate Maria and Michael, the petitioner filed a complaint for
kidnapping, and later on violation of RA 7610, libel, and violation of PD 1829
when Michael obstructed the service of warrant arrest. The Investigating
Prosecutor upheld the charge of violation of RA 7610 but the charge of
Violation of PD 1829 was dismissed. The Provincial Prosecutor denied the
recommendation that Michael Vistan be indicted for Violation RA 7610 but
approved the dismissal of the charge for Violation of PD 1829. Petitioner then
filed a Petition for Review before the Department of Justice but was denied.
The matter was elevated through Petition for Review before the Office of
President but the same was dismissed. The petitioner then filed a petition for
review before the CA assailing the Order of the Office of President. The CA
denied the same.
Issue: Whether or not the dismissal of the complaint of violation of PD 1829
was proper.

Held: Yes, the dismissal of the complaint of violation of PD 1829 was proper.
The SC ruled that there is no jurisprudence that would support the stance
taken by petitioner and that the position taken by petitioner was contrary to
the spirit of the law on "obstruction of justice,". The facts of the case, as
portrayed by petitioner, do not warrant the filing of a separate information
for violation of Section 1(e) of PD No. 1829. This Court agrees with the CA
that based on the evidence presented by petitioner, the failure on the part of
the arresting officer/s to arrest the person of the accused makes the latter a
fugitive from justice and is not equivalent to a commission of another offense
of obstruction of justice.
Padiernos, et. al. vs People, G.R. No. 181111, August 17, 2015 (same sa accessory case)
Facts: Padiernos et. al., were charged as accessories to the crime of illegal
possession of lumber, in violation of PD No. 705 or the Forestry Reform Code
of the Philippines. According to the Information, the petitioners took away
the truck that carried the lumber to prevent its use as evidence and to avoid
its confiscation and forfeiture. The defense argued that they could not be held
liable as accessories because the authorities had already discovered the
crime and had control over the truck when the petitioners drove it. The
prosecution maintains that the petitioners' acts were aimed at preventing the
discovery of the crime. The RTC convicted petitioners Padiernos et. al. as
accessories to the crime of violation of P.D. 705. The RTC found that the
petitioners' testimonies and admissions established their prior knowledge
that the truck had been previously confiscated for illegal transport of forest
products. On appeal, the CA affirmed the conviction.
Issue: Whether or not the accused are accessories to the crime.
Held: No, the accused are not accessories to the crime. The SC ruled that the
Par2 of Article 19 of the RPC provides that the punished acts should have
been committed for the purpose of preventing the discovery of the crime.
However, in this case the crime punishable under P.D. 705 - the illegal
possession of lumber - had already been discovered at the time the
petitioners took the truck. Nevertheless, the factual allegations in the
Information constitute the crime of obstruction of justice under Section
1(b) of P.D. 1829. Section 1(b) of P.D. 1829 provides that the crime of
obstruction of justice may be committed by any person who knowingly or
willfully obstructs, impedes, frustrates or delays the apprehension of
suspects and the investigation and prosecution of criminal cases by
committing any of the following acts:chanxxx
(b) altering, destroying, suppressing or concealing any paper,
record, document, or object, with intent to impair its verity,
authenticity, legibility, availability, or admissibility as evidence in
any investigation of or official proceedings in criminal cases, or
to be used in the investigation of, or official proceedings in
criminal cases; xxx"
Here, the petitioners intentionally suppressed the truck as evidence, with
the intent to impair its availability and prevent its use as evidence in the
criminal investigation or proceeding for violation of P.D. 705.
Noel Navaja vs Hon. De Castro, 180969, September 11, 2017
Facts: DKT Philippines, Inc. (DKT) filed a case of the crime of falsification of a Private
Document against Ana Lou B. Navaja, the wife of the accused Noel Navaja. It was
alleged that on March 9, 2004 the accused went to Ms. Marilyn Magsigay, a material
witness for DKT, and told her that as per instruction from Ana Navaja's lawyer, her
attendance in the scheduled hearing (March 15, 2004) was no longer needed. Thus,
Ms. Magsigay no longer attended the scheduled March 15, 2004 hearing where
petitioner and their lawyer presented a duly executed affidavit by Ms. Magsigay
supporting Ana Navaja's counter-affidavit and the case was dismissed. The lawyer of
DKT found out from Ms. Magsigay what transpired. After due proceedings, two
separate information are filed, one charging the accused of Obstruction of Justice, in
connection with the March 9, 2004 incident; and the second one, charging accused
and their lawyer of Obstruction of Justice as well, in connection with the March 15,
2004 incident. The accused filed a Motion to Quash Information arguing that the two
sets of information involves the same set of facts and circumstances, and flowed from
a single alleged criminal intent. The MTC denied the motion to quash and the RTC
affirmed the same. On appeal to CA, the CA affirmed the RTC Ruling. It held that
accused allegedly committed several acts which constitute violations of different
provisions of PD 1829.
Issue: Whether or not the accused committed several acts which constitute violations
of different provisions of PD 1829.
Held: No, the accused did not commit several acts which constitute violations of
different provisions of PD 1829. The SC ruled that the elements of the violation of PD
1829 are: (a) that the accused committed any of the acts listed under Section 1 of PD
1829; and (b) that such commission was done for the purpose of obstructing,
impeding, frustrating, or delaying the successful investigation and prosecution of
criminal cases. While the two information pertain to acts that were done days apart
and in different locations, the Court holds that petitioner should only be charged and
held liable for a single violation of PD 1829. This is because the alleged acts, albeit
separate, were motivated by a single criminal impulse - that is, to obstruct or impede
the preliminary investigation proceeding which was eventually dismissed. The
foregoing conclusion is premised on the principle of delito continuado, which
envisages a single crime committed through a series of acts arising from one criminal
intent or resolution.