G.R. No. 1564 : April 5, 1904
THE UNITED STATES, complainant-appellee, vs. PEDRO DE LA PATA, ET AL., defendants-appellants.

FACTS:
The defendants, Pedro de la Pata, Leocadio Reyes, and Melquiades Santiago, were employed as domestic servants in the house of Iluminado Cosio. They were charged with the crime of robbery for allegedly opening a locked wooden chest belonging to Cosio and stealing money and jewelry. On April 29, 1902, Cosio discovered that the three servants had abruptly left his service and that the lock of his chest had been broken, with the contents missing. Pedro de la Pata later returned to Cosio’s service, offering only the explanation that he was invited by the others to leave. Leocadio Reyes was arrested five months after the incident, while Melquiades Santiago remained at large. The Court of First Instance convicted Pedro de la Pata and Leocadio Reyes and sentenced them to three years of imprisonment at hard labor. They appealed the decision.

ISSUE:
Was the evidence presented sufficient to prove beyond reasonable doubt that the appellants, Pedro de la Pata and Leocadio Reyes, committed the crime of robbery?

RULING:
No. The Supreme Court reversed the conviction and acquitted the appellants. The Court held that the evidence was insufficient to establish their guilt beyond reasonable doubt. While the simultaneous departure of all three servants was suspicious, this circumstance alone did not conclusively prove that Pedro de la Pata and Leocadio Reyes participated in the robbery. The evidence suggested that Melquiades Santiago, who slept in Cosio’s room and had greater opportunity, was the most probable perpetrator. The Court found a reasonable doubt as to whether the appellants were principals in the crime or merely accessories after the fact. In criminal cases, guilt must be established with moral certainty, and any reasonable doubt must be resolved in favor of the accused. Accordingly, the judgment of the lower court was reversed, and the appellants were acquitted.