G.R. No. 25375 - People vs. De Leon y Flora

On the early morning of December 21, 1925, Vicente de Leon y Flora entered the yard of Vicente Magat’s house on Domingo Santiago Street, Manila.
Without employing violence, intimidation against persons, or force upon things, he took two game roosters.
The act was committed with the intent to gain, fulfilling an essential element of theft.

One rooster had colored plumage and was valued at P8; it belonged to Diego Magat.
The other rooster had white plumage with black spots, valued at P10; it belonged to Ignacio Nicolas.

Vicente de Leon y Flora was initially prosecuted for two separate crimes of theft—one for each rooster.
Upon arraignment, he pleaded guilty and was sentenced in each case to three years, six months, and one day of presidio correctional.
The sentence also required him to return the stolen roosters to their respective owners and to pay the costs in both cases.

The accused appealed from the municipal court’s judgment.
On being arraigned before the Court of First Instance for the same information, he changed his plea to not guilty in both cases.
The trial was conducted jointly by agreement of the parties, as approved by the court.

Based on the evidence, the trial court found that the accused was guilty of one crime of theft, consolidating the two acts into a single offense.
It was determined that taking both roosters in a single act, although belonging to different owners, did not amount to two independent crimes.
Considering the aggravating circumstance of nocturnity and his status as an habitual delinquent, the accused was sentenced to:

Three years, six months, and one day of presidio correctional (initial sentence).
An increased penalty to its maximum degree, namely four years, two months, and one day pursuant to the aggravating factors.
Additionally, an extra penalty of two years and one month was imposed under Act No. 3062 for habitual delinquency.

The accused’s counsel argued that the trial court erred in relying on the accused’s own admission as sufficient proof.
It was contended that the accused was not given the benefit of reasonable doubt.
The counsel further claimed an error in sentencing by not acquitting the accused and in imposing costs de oficio.
Additionally, the Attorney-General argued that the penalty should be imposed for two separate crimes, given that two different owners were involved.

The case was analyzed under the provisions of paragraph 5 of Article 518 (amended by section 1 of Act No. 3244) in connection with paragraph 3 of Article 520 of the Penal Code.
The trial and appellate courts referenced established decisions, including People vs. Aguinaldo and People vs. Espiritu, as well as several Spanish and American jurisprudence cases regarding the unity of criminal acts.

Whether the accused’s own admission could serve as sufficient evidence to prove his guilt beyond a reasonable doubt.

The issue revolves around the legality and sufficiency of using an admission in establishing the criminal act.

Whether the trial court erred in not extending to the accused the benefit of reasonable doubt.

This involves the standard of proof required to convict under the Penal Code and the proper application of evidentiary rules.

Whether taking two roosters, despite belonging to different owners, on the same occasion and in the same place constitutes one or two distinct crimes of theft.

The core issue is the assessment of the unity of criminal intent and act in connection with the multiple items taken.

Whether the imposition of a combined sentence (including the aggravating circumstance of nocturnity and additional penalty for habitual delinquency) is proper in view of the single criminal act.

This issue examines the legal appropriateness of aggregate sentencing based on statutory provisions and precedents.