People v. Arbolante
REITERATIONFacts
The Antecedents: Juan Sellano and Maximo Arbolante were charged with larceny for allegedly taking and appropriating a female carabao calf belonging to Quintin Remolleta. The complaint alleged the act was done willfully, illegally, feloniously, and with intent of gain. Procedural History: During the trial, the complaint against Juan Sellano was dismissed. Maximo Arbolante pleaded not guilty. The Court of First Instance of Cagayan found Arbolante guilty of larceny with the aggravating circumstance of craft, sentencing him to two years and four months of prision correccional. Arbolante appealed. The Petition: The appellant alleged that the lower court erred in finding him guilty and in appreciating the aggravating circumstance of craft.
Issue(s)
Whether the appellant is guilty of the crime of larceny. Whether the aggravating circumstance of craft was present. Whether the appellant took the carabao calf with the intent of gain.
Ruling
The Supreme Court affirmed the conviction of Maximo Arbolante for the crime of larceny but modified the sentence. The Court held that the appellant was guilty of the crime charged and imposed a sentence of four years, two months, and one day of presidio correccional, with accessory penalties and costs.
Ratio Decidendi
On the guilt of the appellant: The Court found that the evidence proved beyond a reasonable doubt that the calf found in the possession of the appellant was the property of Quintin Remolleta and had been stolen from him. The appellant was found in possession of stolen property, and he failed to provide a satisfactory explanation for this possession. The Court reiterated the well-established rule that an individual in possession of stolen property is the principal in the crime of theft unless a satisfactory explanation is given, citing U. S. vs. Soriano, U. S. vs. Molina, U. S. vs. Carreon, and U. S. Soriano and Villalobos. On the intent to gain: The appellant contended that marking the calf with Juan Sellano's mark proved he did not take it with intent to gain. The Court rejected this argument, explaining that the appellant's act of marking the calf with another's mark, without consent, and in the absence of the owner, coupled with the disappearance of Juan Sellano's own calf which had been in the appellant's possession, indicated an attempt to hide his appropriation of Sellano's calf by substituting it with one stolen from Remolleta. The Court reasoned that the intent to gain by taking Remolleta's property was self-evident and undeniable, and that one cannot be excused from the second crime simply because it was committed to cover up the first. The Court stated that if the appellant illegally disposed of the first calf and then stole the second to hide his crime, he committed two crimes, and neither absolved him from the second. On the aggravating circumstance of craft: The lower court found the aggravating circumstance of craft present. While the Supreme Court modified the sentence, it did not explicitly overturn the finding of craft, but rather focused on the elements of the crime and the penalty based on the value of the property stolen and the applicable articles of the Penal Code.
Main Doctrine
An individual in possession of stolen property is presumed to be the principal in the crime of theft unless a satisfactory explanation for such possession is provided. The act of stealing a second item to cover up the theft of a first item does not negate the intent to gain for the second theft.