Facts:

• The case involves The United States vs. Marcelino Dacaimat, G.R. No. 10078, decided on February 5, 1916.
• Marcelino Dacaimat was convicted of theft of large cattle by the lower court.
• A caraballa and her calf were reported stolen from the complainant's corral.
• The calf was found in Dacaimat's possession shortly after the theft.
• Dacaimat claimed the calf was given to him by a man named Dacanay.
• Dacanay denied Dacaimat's account when called as a witness.
• The trial court found Dacaimat guilty based on the evidence, including the presumption of guilt from possession of stolen property.
• Dacaimat appealed, arguing the trial court failed to provide an express finding of facts supporting the judgment.
• The Solicitor-General noted this omission and requested remand to the lower court for correction.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed Dacaimat's conviction for theft.
• The Court determined that the omission of an express finding of facts was not prejudicial to Dacaimat's substantial rights.
• The Court decided against remanding the cas...(Unlock)

Ratio:

• The Supreme Court upheld Dacaimat's conviction, highlighting that possession of recently stolen property creates a presumption of guilt that the accused must explain satisfactorily.
• The trial court's acceptance of Dacanay's testimony over Dacaimat's was considered credible, with no basis to overturn this conclusion.
• Although omissions of findings of fact can...continue reading