G.R. No. L-256 - El Pueblo de Filipinas vs. Magbanua

Around 8:00 PM on November 18, 1945, a carabao belonging to Perpetua Lopez was discovered missing when the animal was found unrestrained; the rope (mecate) used to tie it had been loosened.
The disappearance occurred behind the house of Perpetua Lopez, located in the barrio of Dalig, municipality of Calinog, Province of Iloilo.
Upon noticing the absence of her carabao, Perpetua promptly notified her father, Nemesio Lopez.

Nemesio Lopez, accompanied by his son Fernando Parreno, set out to search for the missing carabao and arrived near 11:00 PM in the municipality of Duenas, approximately 13 kilometers from Dalig.
In Duenas, Parreno spotted the animal in the possession of Felix Magbanua, the appellant, behind the public market.
A confrontation ensued when Parreno, unable to restrain his emotions, grabbed the rope attached to the carabao; Magbanua resisted, leading to a physical altercation.
During the quarrel, Parreno called for help, and a policeman, Emilio Sonza, intervened by arresting both parties and taking them to the municipal house.

Subsequent investigation established that Perpetua Lopez was indeed the owner of the carabao, valued at Php300.
The physical evidence included:

The severed rope found at the scene of the theft.
The proximity in time and location between the reported disappearance and the carabao’s discovery in Magbanua’s custody.

Initially, he claimed to have purchased the carabao for Php130 from a man named Benjamin, with an arrangement to pay the balance upon receipt of proper credentials.
Later, during interrogation by Officer Sonza, he provided an alternate explanation that he had taken the carabao for use as a riding animal, a claim he later negated in open court.

No witnesses corroborated Magbanua’s assertion regarding the purchase, which further undermined the credibility of his defense.
Magbanua also alleged that he was mistreated during the arrest, with claims of being physically abused and robbed of personal effects, although these assertions were not substantiated by independent testimony.

Whether the act committed by Felix Magbanua qualifies as qualified theft of a carabao under the provisions of the Revised Penal Code.
Whether the circumstantial evidence, including physical evidence (severed rope) and the carabao’s location, sufficiently established the appellant’s culpability.

Whether Magbanua’s defense—that he purchased the carabao—was credible and corroborated by evidence or witnesses.
Whether his contradictory statements during police investigation and on the stand undermined his defense.

Whether the penalty imposed by the court, considering the provisions of the Revised Penal Code (Articles 309 and 310) and the Law on Indeterminate Sentence, was proper and just.
Whether the modification of the imposed penalty was warranted based on the applicable legal standards and evidence presented.