Case Digest (G.R. No. 43187)
Facts:
The People of the Philippine Islands v. Anselmo Calalo, G.R. No. 43187, January 29, 1936, the Supreme Court, Recto, J., writing for the Court.On the night of March 31, 1934, in the barrio of Mangahan, municipality of Dolores, Province of Tayabas, a young bull belonging to Eugenio Canoso was stolen and, hours later, was sacrificed. Justo Bulahan and his son Sixto were apprehended as the perpetrators; they were indicted, tried, and convicted by the Court of First Instance of Tayabas for theft and were serving sentence at the time of the instant appeal.
Anselmo Calalo was indicted as a co-principal but was tried separately from the Bulahans. At trial the court found that the evidence did not establish beyond a reasonable doubt that Calalo participated in the taking (i.e., as a principal), but did find that he partook of the subsequent sacrifice. Despite the absence of a finding that Calalo knew of the theft at the time he benefited from the sacrifice, the trial court nevertheless convicted him as an accessory after the fact.
Calalo appealed the judgment to the Supreme Court. The Supreme Court reviewed the trial court's findings and eviden...(Subscriber-Only)
Issues:
- Whether the evidence is sufficient to sustain Calalo's conviction as a principal in the theft of the bull.
- Whether Calalo can be convicted as an accessory after the fact where the record contains no finding or proof that he had knowledge of the commission of the crime at or before the time he pro...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)