Case Digest (G.R. No. 35346) Core Legal Reasoning Model
Facts:
In the case People of the Philippine Islands vs. Pedro Soriano y Sison, decided on September 10, 1931, respondent Pedro Soriano y Sison was charged with frustrated theft in the Court of First Instance of Manila. On or about March 6, 1931, in Manila, Soriano attempted to unlawfully take and carry away a fighting rooster valued at 15 pesos belonging to Antonio Borja. While untying the rooster with the intent to steal, Soriano was surprised by Borja, which caused him to abandon the rooster and flee the premises. Borja and a companion pursued him until he was apprehended by a policeman. Soriano was found guilty of attempted theft and was fined 325 pesetas (equivalent to 65 pesos) with subsidiary imprisonment in case of insolvency, costs, and an additional penalty of twenty-one years imprisonment as an habitual criminal under Act No. 3586, having been previously convicted seven times for theft and once for attempted robbery, with the last conviction dated June 9, 1924. Soriano appea
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Case Digest (G.R. No. 35346) Expanded Legal Reasoning Model
Facts:
- Background of the Case
- Pedro Soriano y Sison was charged before the Court of First Instance of Manila for the crime of frustrated theft.
- The incident occurred on or about March 6, 1931, in the City of Manila, Philippine Islands.
- Details of the Charged Crime
- Soriano was alleged to have willfully, unlawfully, and feloniously taken a fighting rooster valued at P15 owned by Antonio Borja, with intent to gain, and without Borja’s consent.
- Soriano had already performed all acts of execution constituting theft but did not complete the crime due to the intervention of Borja.
- Borja arrived timely, surprised Soriano in the act, causing Soriano to release the rooster and leave it in Borja’s premises.
- Habitual Criminal Allegation
- Soriano was alleged to be an habitual criminal under Act No. 3586.
- He had been convicted seven times for theft and once for attempted robbery within ten years prior to the current case, with the last conviction dated June 9, 1924.
- Proceedings and Trial
- Soriano was provided counsel and trial was held.
- He was found guilty of attempted theft.
- He was sentenced to pay a fine of P65 (or 325 pesetas), with subsidiary imprisonment in case of insolvency, plus costs.
- He was also sentenced to an additional 21 years’ imprisonment as an habitual criminal, pursuant to subsection (d) of Act No. 3586.
- Incident Reconstructed by Evidence
- Early morning of March 6, 1931, Soriano went to Borja’s veranda intending to steal the gamecock.
- Soriano was caught untying the rooster to carry it away, evidencing intent to steal.
- Borja approached and interrupted Soriano.
- Soriano let go of the rooster and fled, pursued by Borja and Aquino.
- Policeman Arcadio Rivero arrived and arrested Soriano.
- Appellant’s Defense
- Argued insufficiency of evidence to sustain conviction.
- Charged the Habitual Delinquency Law as unconstitutional, claiming it:
- Was ex post facto.
- Discriminated.
- Imposed double penalty for the same offense.
Issues:
- Whether the evidence was sufficient to sustain the conviction for attempted theft.
- Whether Act No. 3586 (the Law on Habitual Delinquency) is constitutional, or whether it is ex post facto, discriminatory, or imposes double penalties contrary to law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)