G.R. No. 521 : April 1, 1902
THE UNITED STATES, complainant-appellee, vs. FRANCISCO DE LEON, ET AL., defendants-appellants.

FACTS:
The defendants, Francisco de Leon et al., were convicted by the Court of First Instance of Bataan for the theft of two carabaos valued at 100 pesos. They were sentenced to four months and one day of arresto mayor, indemnification, and costs. The prosecution presented evidence that in April 1901, the carabaos belonging to one Caragay disappeared from a pasture in Balanga and were never recovered. Witnesses testified that around the time of the disappearance, they saw the defendants leading the carabaos away from the pueblo with a rope. The defense presented no evidence during the trial.

While the appeal was pending before the Supreme Court, the defendants filed a petition to reopen the trial based on newly discovered evidence. They alleged that in April 1901, the military authorities had prohibited all persons except soldiers and police from entering or leaving the pueblo of Balanga, and that anyone doing so risked being shot by patrols. They argued this evidence was material to their defense.

ISSUE:
Whether the trial should be reopened on the ground of newly discovered evidence.

RULING:
The Supreme Court denied the petition to reopen the trial and affirmed the judgment of conviction. The Court held that the petition failed to state any facts demonstrating that the alleged newly discovered evidence could not have been obtained with due diligence before the trial in the lower court. The Court also noted the inconclusive character of the proffered evidence. Consequently, the conviction was upheld, with costs against the appellants.