G.R. No. L-5813, THE UNITED STATES, plaintiff-appellee, vs. SANTIAGO ESPIA, defendant-appellant., August 27, 1910

FACTS:
Defendant Santiago Espia was charged with the crime of larceny for stealing a carabao valued at P150, owned by Liberto Ortizo. The carabao was stolen from Ortizo on or about December 24, 1908. In August 1909, the stolen carabao was found in the possession of the defendant. Espia was unable to provide any satisfactory explanation as to how he acquired possession of the carabao. The Court of First Instance of Iloilo found him guilty and sentenced him to six months of arresto mayor and to pay the costs. Espia appealed the conviction.

ISSUE:
Whether the unexplained possession of a recently stolen carabao is sufficient proof to justify a conviction for the crime of larceny.

RULING:
Yes. The Supreme Court affirmed the judgment of the lower court. The Court ruled that it being proven that the carabao was stolen, and subsequently found in the possession of the defendant without him being able to give a satisfactory explanation as to how he came into possession of the same, is sufficient proof to justify his conviction for the crime of larceny. The Court emphasized that individuals who honestly acquire possession of property typically have no difficulty in explaining how they obtained it.