G.R. No. 1225 : August 21, 1903
THE UNITED STATES, complainant-appellee, vs. SATURNINO DE LA CRUZ, ET AL., defendants-appellants.

FACTS:
The defendants-appellants were charged with and convicted of the crime of brigandage under Act No. 518. The prosecution presented evidence showing the existence of an armed band commanded by Saturnino de la Cruz, with his co-defendants as members. This band was involved in an incident where a Chinaman named Barretto was sequestered and compelled to join the Bulacan branch of the Katipunan Society. Barretto was released after signing the Katipunan book, without any loss of his personal property. For defendant Basilio Reyes, the only evidence presented was that a dagger was found in the house where he was arrested.

ISSUE:
Whether the prosecution sufficiently proved all the essential elements of the crime of brigandage, particularly the aim and purpose of the armed band to commit robbery by means of force and violence, as required under Act No. 518.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted all defendants of the charge of brigandage. The Court, concurring with the Solicitor-General’s analysis, held that while evidence established the existence of an armed band and the defendants’ membership therein, the prosecution failed to present any proof that the band’s aim and purpose was to commit robbery. The incident involving Barretto, where he was forced to join the Katipunan but was released without being robbed, indicated a purpose contrary to robbery. Since proof of the specific criminal intent to rob is an essential element of brigandage under Act No. 518, the conviction could not be sustained. As to Basilio Reyes, the evidence was even more insufficient, being limited to the discovery of a dagger. The Court noted that, except for Basilio Reyes, there was evidence on record that might support prosecution for other crimes, such as rebellion or insurrection under Act No. 292, and possibly murder.