GR 2086; (September, 1905) (Digest)
March 6, 2026GR 2078; (September, 1905) (Digest)
March 6, 2026G.R. No. 2100
Date: September 15, 1905
Parties:
– Plaintiff-Appellee: The United States
– Defendants-Appellants: Matias de la Cruz and Crisanto Corpus
FACTS:
On April 19, 1904, a police officer filed a complaint charging Matias de la Cruz and Crisanto Corpus with the crime of theft. The accusation alleged that the defendants, with intent to gain and without the owner’s knowledge, stole a diamond ring valued at 550 pesos and a sapphire-and-diamond ring valued at 250 pesos (both in Mexican currency), for a total value of 800 pesos (equivalent to 4,000 pesetas). After trial, the court acquitted Crisanto Corpus but convicted Matias de la Cruz, sentencing him to two years of prision correccional. The trial court did not order restitution of the stolen items or their value, nor did it impose costs. Matias de la Cruz appealed the judgment.
ISSUE:
Whether the evidence presented, particularly the alleged extrajudicial confession of Matias de la Cruz, is sufficient to prove his guilt beyond reasonable doubt for the crime of theft.
RULING:
The Supreme Court REVERSED the conviction and ACQUITTED Matias de la Cruz.
The Court held that the evidence was insufficient to establish the guilt of Matias de la Cruz. The prosecution relied heavily on an extrajudicial confession allegedly made by de la Cruz to a police officer, G. William Marshall. However, de la Cruz repudiated this confession, claiming it was extracted under maltreatment by another police officer. Applying Section 4 of Act No. 619 (enacted February 6, 1903), the Court emphasized that a confession is admissible only if it is shown to be freely and voluntarily made, without violence, intimidation, threat, menace, or promises of reward or leniency. The record failed to demonstrate that the confession met these requirements; thus, it was inadmissible as evidence.
Moreover, the Court found no other satisfactory evidence linking de la Cruz to the theft. The owner’s testimony that a key possibly used to open the jewelry box was found in the possession of the acquitted co-accused, Crisanto Corpus, did not implicate de la Cruz. There was no proof that de la Cruz possessed or used such a key.
Invoking the presumption of innocence under Section 57 of General Orders No. 58, the Court ruled that any reasonable doubt must be resolved in favor of the accused. Since the evidence failed to overcome this presumption, de la Cruz was entitled to acquittal. The case was remanded to the lower court for execution of the acquittal, with costs de oficio.
Concurring Justices: Arellano, C.J., Mapa, Johnson, Carson, and Willard.
