G.R. No. 1755 : April 19, 1905

FACTS:
The defendants, Santiago de la Cruz and Jose Aquino de la Rosa, were charged with the crime of robbery for stealing 30 pesos from Juliana de la Cruz, which she carried in her waist. The trial court convicted the defendants based primarily on the testimony of the injured party, Juliana de la Cruz. The defendants appealed the judgment.

ISSUE:
Whether the trial court erred in: (1) convicting the defendants based on the testimony of the injured party; and (2) imposing the correct penalty, considering the defendants’ previous conviction for abduction.

RULING:
The Supreme Court AFFIRMED the conviction but MODIFIED the penalty.

1. On the Sufficiency of Evidence: The Court held that the testimony of the injured party alone can be sufficient to establish the guilt of the accused, citing precedents in United States vs. Ignacio Dacotan (1 Phil. Rep., 669) and United States vs. Geronimo Torrente (2 Phil. Rep., 1). Therefore, the trial judge did not err in relying on Juliana de la Cruz’s testimony to convict the appellants.

2. On the Proper Penalty: The Court found that the trial court erred in its application of the penalty. The fact that the defendants had a prior conviction for abduction was not a mitigating circumstance that would warrant a reduction of the penalty. Applying the relevant provisions of the Penal Code (Article 502 and paragraph 5 of Article 503), the Supreme Court imposed the correct penalty.

DISPOSITIVE PORTION:
The Supreme Court sentenced Santiago de la Cruz and Jose Aquino de la Rosa to three years, eight months, and one day of presidio correccional, with its accessory penalties. They were further ordered to reimburse the stolen amount of 30 pesos to Juliana de la Cruz and to pay the costs of the proceedings in both instances pro rata.