Case Digest (G.R. No. L-1542)
Facts:
- Jose Cristobal was accused of being an accessory to theft.
- The principal accused, Jose Martinez, had his case dismissed due to insufficient evidence.
- In April 1945, Mrs. Carmen M. de Caro discovered her diamond ring was stolen from her handbag under her mattress in Manila.
- Suspicion fell on her son, Rolando Caro, who confessed and said he sold the ring to Cristobal for P800.
- Mrs. Caro and her lawyer confronted Cristobal, who admitted to buying the ring and agreed to let her redeem it for the same amount.
- When Mrs. Caro gathered the money, Cristobal claimed the ring had been sold for P1,200 by his agent, whose identity he could not provide.
- Mrs. Caro reported the matter to the authorities, leading to Cristobal's prosecution.
- The Court of First Instance of Manila convicted Cristobal, sentencing him to three years, six months, and twenty-one days of destierro and ordering him to indemnify Mrs. Caro P3,000.
- The Court of Appeals affirmed the conviction but reduced the indemnity to P2,000.
- Cristobal sought a review by the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court upheld that Cristobal disposed of the ring knowing it was stolen.
- Cristobal was correctly found guilty as an accessory to theft.
- The previous dismissal for lack of jurisdiction did not constitute double jeopardy.
- The dismissal of the case against Jose Martinez and the non-inclusion of Francisco Cueva were not preju...(Unlock)
Ratio:
- The Supreme Court emphasized that the findings of fact by the Court of Appeals are final and conclusive. The evidence showed Cristobal disposed of the ring after being informed it was stolen, making him guilty as an accessory.
- Under Article 19 of the Revised Penal Code, an accessory is someone who, knowing the commission of a crime, assists the offender to profit from the effects of the crime. Cristobal's actions fit this definition as he disposed of the ring after knowing it was stolen.
- The dismissal of the case in the municipal court was based on lack of jurisdiction, which does not bar sub...continue reading
Case Digest (G.R. No. L-1542)
Facts:
In the case of "Cristobal v. People," the petitioner, Jose Cristobal, was accused of being an accessory to the crime of theft. The principal accused, Jose Martinez, had his case dismissed due to insufficient evidence. The incident occurred in April 1945 in Manila, where Mrs. Carmen M. de Caro discovered that her diamond ring, kept in a handbag under her mattress, had been stolen. Suspicion fell on her 20-year-old son, Rolando Caro, who confessed to the theft and revealed that he had sold the ring to Jose Cristobal, a silversmith, for P800. Mrs. Caro and her lawyer confronted Cristobal, who admitted to buying the ring and agreed to let her redeem it for the same amount. However, when Mrs. Caro managed to gather the money, Cristobal claimed the ring had already been sold for P1,200 by his agent, whose identity and address he could not provide. Consequently, Mrs. Caro reported the matter to the authorities, leading to Cristobal's prosecution as an accessory to theft. The Court of First Instance of Manila convicted Cristobal, sentencing him to three years, six months, and twenty-one days of destierro and ordering him to indemnify Mrs. Caro P3,000. The Court of Appeals affirmed the conviction but reduced the indemnity to P2,000. Cristobal then sought a review of the sentence by the Supreme Court.
Issue:
- Did Jose Cristobal dispose of the ring knowing it was stolen?
- Was Cristobal correctly found guilty as an accessory to theft?
- Does the previous dismissal of the case in the municip...