Ordonio v. Court of Appeals
REITERATIONFacts
The Antecedents: On January 5, 1982, Anastacio Pajunar discovered his eleven-month-old cow missing from where it was pastured. He inquired from his neighbor, Constancio Ordonio, who initially denied seeing the cow. Pajunar later found the cow tied near Ordonio's house. Ordonio claimed it was his brother's cow entrusted to him. Pajunar tied the cow near Ordonio's house and reported the matter to the authorities. With the assistance of barangay officials and PC soldiers, the cow was retrieved. Upon arrival at Ordonio's place with the milking cow, the calf ran to its mother. Ordonio's wife consented to entrust the calf to a barrio official. The following day, Ordonio continued to insist the cow belonged to his brother, but his wife suggested returning it to the owner and paying damages. Procedural History: Constancio Ordonio was indicted for cattle rustling. The trial court found him guilty of violating Presidential Decree No. 533 and sentenced him to imprisonment. The trial court conducted a new trial based on newly discovered evidence, but maintained its conviction. Ordonio appealed to the Court of Appeals, assigning errors regarding the presumption of elements of the crime, the reliance on the weakness of the defense's evidence, and the misapprehension of facts. The Court of Appeals affirmed the trial court's decision in toto. Ordonio then filed a petition for review on certiorari before the Supreme Court. The Petition: The accused-petitioner argued that the lower courts misapprehended facts, specifically that the actual taking of the calf was not proven, and that finding the calf tied on his property or stepping on the rope did not constitute theft. He claimed the animal had strayed, destroyed his plants, and he merely tied it to prevent further damage, intending to return it. He also alleged the complainant filed the case out of spite due to a land dispute and attempted blackmail.
Issue(s)
Whether the Supreme Court can review the factual findings of the Court of Appeals in a petition for review on certiorari under Rule 45. Whether the accused-petitioner is guilty of cattle rustling under Presidential Decree No. 533.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of Constancio Ordonio for cattle rustling.
Ratio Decidendi
On the issue of reviewing factual findings under Rule 45: The Supreme Court reiterated that in petitions for review on certiorari under Rule 45 of the Rules of Court, the review is generally limited to errors of law committed by the Court of Appeals. Factual findings of the trial court, especially when confirmed by the Court of Appeals, are considered conclusive and generally not subject to review. While exceptions exist, such as misapprehension of facts, the Court found no such misapprehension in this case. The Court emphasized that its role is not to re-examine the evidence presented by the parties, particularly when the findings of the lower courts are consistent and supported by the records. The Court's focus remains on whether the law was correctly applied to the established facts. On the guilt of the accused-petitioner for cattle rustling: The Supreme Court found that the prosecution proved the guilt of the accused beyond reasonable doubt. The conviction was not based on the mere finding of the calf tied on the accused's premises or his alleged stepping on the rope, but on his actuations when the calf was found in his possession. These actuations included twice denying knowledge of the calf, refusing to return it by claiming it belonged to his brother, and only admitting ownership after the complainant proved it. The Court highlighted that the calf's conduct of running to its mother to suckle further confirmed its ownership by the complainant. The Court defined cattle rustling under Section 2(c) of P.D. 533 as "taking away by any means, methods or schemes, without the consent of the owner/raiser, of any of the above mentioned animals whether or not for profit or gain." The Court inferred the intent to gain from the deliberate failure to deliver the lost property to the proper person, knowing it did not belong to him. The accused's stubborn insistence that the calf belonged to his brother, despite knowing it belonged to the complainant, was deemed sufficient to establish the elements of cattle rustling.
Main Doctrine
The stubborn insistence of an accused that a missing calf belonged to his brother, knowing fully well that it belonged to the complainant, constitutes cattle rustling under Presidential Decree No. 533, as it demonstrates an intent to appropriate the animal.