Title
People vs. Rodrigo
Case
G.R. No. L-18507
Decision Date
Mar 31, 1966
Appeal over dismissal of theft complaint; court ruled intent to gain inferred from failure to return stolen horse, remanding case.
A

Case Digest (G.R. No. L-18507)

Facts:

  • Initiation and nature of the criminal complaint
    • The Solicitor General appealed from an order of the Court of First Instance of Masbate.
    • The Court of First Instance of Masbate affirmed an order of the Justice of the Peace Court of Pio V. Corpuz, which dismissed an amended complaint.
    • The amended complaint accused Romualdo Rodrigo of the crime of theft of large cattle.
    • The amended complaint alleged that, on or about March 8, 1960, and in months previous, at Tubod, Pio V. Corpuz, Masbate, and within the jurisdiction of the court, Romualdo Rodrigo:
      • Kept in his possession one male horse specifically described under Certificate of Ownership of Large Cattle No. 4685981.
      • Had possession of the horse which allegedly legally belonged to Felix Muertigue.
      • Knew that the horse was stolen from the ranch of Felix Muertigue at Casabangan, Pio V. Corpuz, Masbate.
      • Deliberately failed to deliver the horse either to the authorities or to its owner.
      • Caused damage and prejudice to the owner in an amount of not less...(Subscriber-Only)

Issues:

  • Sufficiency of the amended complaint under Rule 110
    • Whether the lower courts erred in ruling that the amended complaint was defective because the element of “intent to gain” was not alleged.
  • Applicability of the “lost property” theft provision to a horse alleged to have been stolen
    • Whether the complaint, which referred to a stolen horse, could properly be charged under the theft provision involving finding of lost property.
    • Whether “lost property”...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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