People v. Pil-ey
REITERATIONFacts
The Antecedents: Petitioner Ernesto Pil-ey, along with co-accused Constancio Manochon and Waclet Anamot, was charged with violation of Presidential Decree No. 533, the Anti-Cattle Rustling Law. The Information alleged that on or before April 15, 1994, the accused conspired to steal and butcher one cow belonging to Rita Khayad, causing her damage amounting to P10,000.00. The prosecution presented evidence that the victim discovered her cow missing on April 16, 1994. Her grandson reported seeing a cow matching the description loaded into a Ford Fiera driven by Manochon, with Pil-ey as a passenger. The cow was subsequently found to have been slaughtered. Procedural History: The Regional Trial Court (RTC), Branch 36, Bontoc, Mountain Province, found all three accused guilty beyond reasonable doubt of violating P.D. No. 533 and sentenced them to an indeterminate imprisonment of ten (10) years and one (1) day to twelve (12) years, five (5) months, and eleven (11) days, jointly and severally liable for P10,000.00 in damages, and to pay costs. The accused appealed this decision. The Court of Appeals (CA) affirmed the RTC's ruling in its entirety on November 29, 2001. The accused filed separate motions for reconsideration, which were denied. Subsequently, Constancio Manochon's petition for review on certiorari was denied by the Supreme Court for failure to submit required documents and for raising factual issues. Waclet Anamot's petition was also denied for failure to pay docket fees. This left only Ernesto Pil-ey's petition for review on certiorari for resolution. The Petition: Petitioner Ernesto Pil-ey filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the decision of the Court of Appeals. He raises three main issues: (1) whether his offer of compromise during custodial investigation, made without counsel, constitutes an implied admission of guilt and is admissible; (2) whether the CA erred in applying the legal presumption of guilt under Section 7 in relation to Section 5 of P.D. No. 533; and (3) whether the CA erred in affirming the trial court's decision despite insufficient evidence for conviction. Pil-ey reiterates his and Manochon's defense that they mistakenly believed the cow belonged to Anamot, who had offered it for sale and butchering.
Issue(s)
Whether the offer of compromise made by the petitioner is an implied admission of guilt, especially considering it was made during custodial investigation without observance of his rights. Whether the Court of Appeals erred in applying the legal presumption of guilt under Section 7 in relation to Section 5 of P.D. No. 533. Whether the Court of Appeals erred in affirming the trial court's decision despite the evidence on record not supporting a conviction.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding the petitioner guilty beyond reasonable doubt of violating P.D. No. 533. However, the Court modified the penalty imposed by the lower courts.
Ratio Decidendi
On Whether the offer of compromise made by the petitioner is an implied admission of guilt, especially considering it was made during custodial investigation without observance of his rights: The Court ruled that the petitioner's argument regarding the inadmissibility of his offer of settlement made during an informal confrontation at the police station is no longer material. This is because the crime of cattle-rustling and the fact that the petitioner and his co-accused were the perpetrators thereof had been established by ample evidence other than the alleged inadmissible extrajudicial confession. The conviction was supported by other evidence, rendering the issue of the admissibility of the offer of compromise moot. On Whether the Court of Appeals erred in applying the legal presumption of guilt under Section 7 in relation to Section 5 of P.D. No. 533: The Court affirmed the application of the presumption of guilt. It held that when stolen property is found in the possession of one who is not the owner, and without a satisfactory explanation of such possession, that person is presumed to be the thief. This is in consonance with the disputable presumption that a person found in possession of a thing taken in the doing of a recent wrongful act is the taker and the doer of the whole act. The defense of mistake of fact, that they believed the cow belonged to Anamot, was found unacceptable based on Anamot's testimony. On Whether the Court of Appeals erred in affirming the trial court's decision despite the evidence on record not supporting a conviction: The Court found that the evidence on record sufficiently proved the guilt of the petitioner and his co-accused beyond reasonable doubt. The prosecution proved that Rita Khayad's cow was taken without her consent and was later found in the possession of the petitioner and his co-accused. The petitioner's admission during the trial that they took the cow, corroborated by the testimony of a prosecution witness who saw them with the cow in a vehicle, further reinforced the conviction. The Court reiterated that conviction for cattle-rustling needs only to be supported by the fact of taking without the owner's consent.
Main Doctrine
The possession of stolen large cattle without a satisfactory explanation creates a presumption of guilt for cattle rustling. An offer of compromise made during informal confrontation at the police station, even if without counsel, is not material if guilt is established by other ample evidence. The penalty for cattle rustling should be computed in accordance with the Revised Penal Code, not solely as a special law.