Case Digest (G.R. No. 10078)
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
Case Digest (G.R. No. 10078)
Facts:
In the case of The United States vs. Marcelino Dacaimat, G.R. No. 10078, decided on February 5, 1916, the appellant, Marcelino Dacaimat, was convicted of theft of large cattle in the lower court. The incident occurred when a caraballa and her calf were reported stolen from the corral of the complaining witness. Shortly after the theft, the calf was discovered in Dacaimat's possession. During the trial, Dacaimat claimed that the calf had been given to him by a man named Dacanay. However, Dacanay, when called as a witness, denied Dacaimat's account of how he obtained the calf. The trial court found Dacaimat guilty based on the evidence presented, which included the presumption of guilt arising from the possession of the stolen property shortly after the theft. The trial judge accepted Dacanay's testimony as credible and rejected Dacaimat's defense. Dacaimat appealed the conviction, arguing that the trial court had failed to provide an express finding of facts that supported the judgment. The Solicitor-General also noted this omission and requested that the case be remanded to the lower court for correction.
Issue:
- Di...