GR L 10005; (November, 1914) (Digest)
G.R. No. L-10005; November 9, 1914
THE UNITED STATES, plaintiff-appellee, vs. ANDRES MANLUCO, ET AL., defendants. ANDRES MANLUCO, appellant.
FACTS:
The appellant, Andres Manluco, along with others, was charged with the crime of robbery. The information alleged that on or about October 16, 1913, in Hermosa, Bataan, the accused, with intent to gain and by means of force and intimidation, took one piece of narra timber (about 4 meters long and 60 centimeters thick) valued at ₱70, which belonged to Teodoro David and was under the custody of his employee, Sabas Fonseca. The Court of First Instance of Bataan convicted Manluco and sentenced him to presidio correccional for three years, eight months, and one day, with accessories, restitution of the timber or its value, and payment of half the costs. Manluco appealed.
ISSUE:
Whether the accused’s act of taking the timber constitutes the crime of robbery, considering his claim of ownership over the property taken.
RULING:
The Supreme Court REVERSED the judgment of conviction and ACQUITTED the accused. The Court held that for robbery or larceny to exist, there must be criminal intent (animus lucrandi). If a person takes property openly and avowedly under a claim of ownership made in good faith, the act lacks criminal intent, even if the claim later proves to be untenable. In this case, the evidence sufficiently demonstrated that Manluco acted in good faith, believing himself to be the owner of the timber, and that the taking was done openly under that claim. This deprived the act of criminality. The Court found it unnecessary to definitively resolve the question of actual ownership, as the showing of good faith was sufficient to acquit. Costs were ordered de officio.
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