Title
People vs. Soriano y Sison
Case
G.R. No. 35346
Decision Date
Sep 10, 1931
Pedro Soriano, a repeat offender, attempted to steal a rooster in 1931. Convicted of attempted theft, he challenged the Habitual Delinquency Law's constitutionality. The Supreme Court upheld his conviction and the law's validity, affirming additional penalties for habitual criminals.

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)

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