People v Madali

GR No. 67803-04
July 30 1990
Fernan, C.J.,:

Facts: On October 26 1979 the son, Ramon, of the co-accused, Ricarte and Annie Madali, got
into a fight with Felix. Agustin, one of the victims, was a friend of Felix. Felix and Agustin were
brought to the police station where they met co-accused Ricarte. Ricarte told the 2 that they
should be filled with bullets. On October 31 1979, the victim went home. On his way home, he
went to buy cigarettes and ran into Ricarte. Ricarte pulled the victim to his house where his wife
Annie attacked the latter with a piece of wood. Agustin tried to escape but was shot by Ricarte.
After hearing the shot, Felix Gasang arrived and Annie beamed her light towards him and said
"Here comes another ''. Ricarte shot Felix Gasang as well. Cipriano Gasang and his daughter,
Merlinda, also arrived and Annie beamed her flashlight to which and said "Here comes another,
fire upon him". Ricarte shot Cipriano as well. Cipriano's daughter was alos hit by the same
bullet. Cipriano and Felix both died but Agustin and Merlinda survived due to timely medical
intervention. The police arrived at the scene and Ricarte surrendered his weapon. The co-
accused were found guilty of 2 counts of murder and 2 counts of frustrated murder.

Issue: Is Annie Madali liable for murder by inducement?

Ruling: No, Annie Madali is not liable for murder by inducement.

There is no proof that those inciting words had great dominance and influence over Madali as to
become the determining cause of the crimes. The rapidity with which Madali admittedly fired the
shots eliminated the necessity of encouraging words such as those uttered by Annie.

Ricarte Madali could have nevertheless accomplished his criminal acts without Annie's
cooperation and assistance.—Annie's participation in the shooting of the victims consisted of
beaming her flashlight at them and warning her husband of the presence of other persons in the
vicinity. By beaming her flashlight at a victim, Annie assisted her husband in taking a good aim.
However, such assistance merely facilitated the commission of the felonious acts of shooting.
Considering that, according to both of the Madali spouses, "it was not so dark nor too bright"
that night or that "brightness and darkness were equally of the same intensity." Ricarte Madali
could have nevertheless accomplished his criminal acts without Annie's cooperation and
assistance.