Case Summary (B.M. No. 3288)
Key Dates
The judgment under appeal was rendered on November 6, 1981.
Applicable Law
The decision is governed by Presidential Decree No. 533, also known as the Anti-Cattle Rustling Law of 1974, along with relevant provisions from the Revised Penal Code of the Philippines, particularly the Indeterminate Sentence Law.
Procedural Background
Macatanda was convicted for the crime of cattle rustling and sentenced to an indeterminate penalty of six years and one day of prision mayor as the minimum, up to eight years of prision mayor as the maximum. He appealed the conviction primarily on legal grounds, including the assertion of mitigating circumstances related to his education and cultural background.
Factual Background
The case arose from an incident on December 25, 1976, when the complainant's two carabaos were discovered missing. They were later found in the possession of Macatanda and his companions, who engaged in a gun battle with law enforcement, resulting in Macatanda's apprehension and subsequent guilty plea.
Arguments on Mitigating Circumstances
Macatanda argued for the recognition of two mitigating circumstances: lack of instruction and cultural minority status as a Muslim. He referenced the case of U.S. vs. Maqui to support his argument for leniency. However, the court distinguished his case from Maqui, noting that no evidence of lack of instruction was presented, as all circumstances must be substantiated by evidence.
Dispute on Legal Precedent
The court disallowed the application of the Maqui precedent because the prior ruling involved an "uncivilized" status that warranted consideration of lack of instruction. The court stated that mere cultural minority status does not inherently imply a lack of education or responsibility.
Calculation of Penalty
Macatanda contended that the penalty computation should follow Article 64 of the Revised Penal Code. The Solicitor General maintained that this article was not applicable since P.D. 533 constituted a special law. However, the court found that P.D. 533 should be considered as s
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Case Overview
- This case involves Saglala Macatanda, who was charged and convicted of cattle rustling under Presidential Decree No. 533 in the Court of First Instance of Lanao del Norte, Branch IV in Iligan City.
- Macatanda pleaded guilty to the charge and received a sentence of imprisonment ranging from six years and one day to eight years of prision mayor, with the possibility of crediting preventive imprisonment.
Facts of the Case
- On the evening of December 25, 1976, the complainant left two carabaos near his house in Salug, Sapad, Lanao del Norte, only to discover they were missing the following morning.
- The complainant reported the loss to Welfredo Bucol, the team leader of the constabulary home defense unit, and joined a search posse to locate the stolen carabaos.
- The posse found Macatanda and three others in possession of the carabaos in Pawak, Salvador, Lanao del Norte, leading to a confrontation that resulted in a gun battle where Macatanda was wounded.
- Macatanda's companions fled, leaving him and the carabaos behind, after which he was taken into custody and charged with cattle rustling.
Legal Issues Raised on Appeal
- Macatanda appealed the conviction, raising legal questions regarding the consideration of mitigating circumstances:
- Lack of instruction.
- Being a member of a cultural minority (specifically a Moslem).
- He argued these factors should have been appreciated in his favor, which the tri