G.R. No. 1656 : April 2, 1904
THE UNITED STATES, complainant-appellee, vs. MARIANO DE LA CRUZ, defendant-appellant.

FACTS:
The defendant, Mariano de la Cruz, was charged with violating Section 4 of Act No. 518 (the Brigandage Act) for allegedly giving information and furnishing supplies and money to a band of brigands led by Faustino Guillermo. The trial court convicted him based on evidence that he obtained twenty-five pesos (₱25) from Juan Dizon and sent it to Guillermo after the law took effect. The defendant was sentenced to fourteen years and six months of imprisonment. On appeal, the defense challenged the sufficiency of evidence. Furthermore, evidence presented at trial also suggested that about two months after the alleged money transfer, the defendant participated in a nighttime forcible taking of money from Juan Dizon’s house, though witnesses could not confirm if the perpetrators were armed.

ISSUE:
1. Whether the act of furnishing money to a band of brigands constitutes an offense under Section 4 of Act No. 518 .
2. Whether the defendant can be convicted of the crime of simple robbery under a complaint that solely charges him with furnishing information and supplies to brigands.

RULING:
The Supreme Court reversed the judgment of conviction and acquitted the defendant.
1. On the charge of violating Act No. 518 : The Court held that even assuming the evidence was sufficient to prove that the defendant sent money to the brigand leader, such an act did not constitute an offense under Section 4 of Act No. 518 . This ruling was based on prior jurisprudence (United States vs. Agaton Ambata, et al.).
2. On the possibility of a conviction for simple robbery: The Court ruled that a conviction for simple robbery under the Penal Code cannot be sustained under the complaint filed. The complaint was limited to charging the defendant with furnishing information and supplies; it did not allege any act of robbery or even his membership in a brigand band. A robbery charge is not necessarily included in the offense charged. To convict him of robbery based on the evidence presented would violate his right to be informed of the nature and cause of the accusation against him, as the complaint gave him no notice that he would have to defend against a specific robbery allegation.

The defendant was acquitted, with costs de oficio. The acquittal was without prejudice to the filing of a separate complaint against him for the crime of simple robbery.

Separate Concurring Opinion:
Chief Justice Arellano and Justices Torres and Mapa concurred in the result of acquittal due to lack of sufficient evidence for the crime charged. However, they expressly did not concur with the majority’s doctrine that furnishing money to a band of brigands is not a crime under Section 4 of Act No. 518 .