Case Digest (G.R. No. 140937)
Facts:
Exuperancio Canta v. People of the Philippines, G.R. No. 140937, February 28, 2001, the Supreme Court Second Division, Mendoza, J., writing for the Court. Petitioner is Exuperancio Canta; respondent is the People of the Philippines.The prosecution charged petitioner with violation of P.D. No. 533 (Anti‑Cattle Rustling Law of 1974) for allegedly taking on or about March 14, 1986 one black female cow belonging to Narciso Gabriel. The cow was born March 10, 1984 and, after birth, was cared for sequentially by several caretakers (Erlinda Monter, Generoso Cabonce, Maria Tura, and Gardenio Agapay). On the morning of March 14, 1986, Agapay discovered the cow missing and traced hoof prints to the house of Filomeno Vallejos; he was told that petitioner had taken the animal.
Gardenio and Maria Tura, acting on the owner’s instructions, sought recovery from petitioner’s wife and were told petitioner had delivered the cow to his father, Florentino Canta (then barangay captain). They met petitioner, who accompanied them to his father’s home and then failed to follow up. Narciso reported the loss to police; both Narciso and petitioner were summoned. Petitioner admitted taking the cow but asserted ownership, producing certificates of ownership (one dated February 27, 1985 and another dated March 17, 1986).
At trial, the prosecution introduced a certificate of ownership for Narciso dated March 9, 1986 showing identifying cowlick marks, and testimony by four caretakers who identified the animal by color, sex and the location of cowlicks. The municipal treasurer denied any registration in petitioner’s name; Franklin Telen (a municipal hall janitor) admitted issuing a certificate to petitioner only after the March 14, 1986 taking and that he antedated it at petitioner’s instance. Petitioner claimed an alternate theory of acquisition (an agreement with Pat. Diosdado Villanueva) and testified he took the cow on March 14, 1986 believing it to be his, brought a mother cow to test suckling, and turned the animal over to his father and later to authorities.
The Regional Trial Court, Branch 25, Maasin, Southern Leyte (Judge Numeriano R. Avila, Jr.), found petitioner guilty on January 24, 1997 and imposed a penalty of ten (10) years and one (1) day of prision mayor, as minimum, to twelve (12) years, five (5) months, and eleven (11) days of reclusion temporal medium, as maximum, plus costs. The Court of Appeals affirmed its decision in a decision dated ...(Subscriber-Only)
Issues:
- Did the prosecution prove beyond reasonable doubt the elements of cattle rustling under P.D. No. 533 against petitioner?
- Was petitioner’s asserted good faith or mistake of fact a valid defense that negates criminal liability?
- Was the penalty imposed by the trial court proper, and should petitioner be credited with a mitigating circumstance anal...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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