In QUIDET vs. PEOPLE OF THE PHILIPPINES (G.R. No.

170289, April 8, 2010), the High

Court explained that the conspiracy itself must be proven beyond reasonable doubt.
Thus:

Conspiracy must be proved as clearly and convincingly as the commission of the

offense itself for it is a facile device by which an accused may be ensnared and
kept within the penal fold. In case of reasonable doubt as to its existence, the
balance tips in favor of the milder form of criminal liability as what is at stake
is the accused�s liberty. We apply these principles in this case.

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Conspiracy exists when two or more persons come to an agreement concerning the
commission of a felony and decide to commit it. The essence of conspiracy is the
unity of action and purpose. Its elements, like the physical acts constituting the
crime itself, must be proved beyond reasonable doubt. When there is conspiracy, the
act of one is the act of all.

Conspiracy can be inferred from and established by the acts of the accused
themselves when said acts point to a joint purpose and design, concerted action and
community of interests. However, in determining whether conspiracy exists, it is
not sufficient that the attack be joint and simultaneous for simultaneousness does
not of itself demonstrate the concurrence of will or unity of action and purpose
which are the bases of the responsibility of the assailants. What is determinative
is proof establishing that the accused were animated by one and the same purpose.

PEOPLE OF THE PHILIPPINES vs. ARNEL VILLALBA (G.R. No. 207629, October 22, 2014)

On conspiracy

Jurisprudence requires that conspiracy must be proven as the crime itself.

Conspiracy exists when two or more persons come to an agreement concerning the
commission of a crime and decide to commit it. Proof of the agreement need not rest
on direct evidence, as the same may be inferred from the conduct of the parties
indicating a common understanding among them with respect to the commission of the
offense. It is not necessary to show that two or more persons met together and
entered into an explicit agreement setting out the details of an unlawful scheme or
the details by which an illegal objective is to be carried out. The rule is that
conviction is proper upon proof that the accused acted in concert, each of them
doing his part to fulfill the common design to kill the victim.