Ana and Cristo, married for 20 years, had marital disputes. Wanting to end their marriage, Ana contacted Berto, a hitman, and offered him money to kill Cristo. At 9:30 PM in a well-lighted grass area, Diego and Earl saw Ana and Berto 7-meters away on standby and heard Ana mention Cristo’s name, and uttered the words: “Pagbabalakan patayin”, “Bilis, baka may makakita”, and “Yariin mo na”. Upon Cristo’s arrival, Berto approached Cristo and took him to a dark area at gunpoint. Thirty minutes later, Diego and Earl heard a gunshot and hid under the grassy area. Ana was later arrested and charged with Parricide after she was identified by Diego and Earl. In her defense, she argued that she cannot be convicted as the principal because she did not pull the trigger, and that her outbursts during the shooting were done out of panic and does not constitute a command.

Is Ana liable as a principal by inducement? (Bar 2026 Syllabus)