GR L 11636; (February, 1917) (Digest)
G.R. No. L-11636; February 28, 1917
THE UNITED STATES, plaintiff-appellee, vs. SANG KUPANG MAMBANG, defendant-appellant.
FACTS:
The defendant-appellant, Sang Kupang Mambang, was convicted by the trial court of the crime of theft of large cattle (a carabao) and was sentenced to four years and ten months of presidio correccional and to pay an indemnity of P80, representing the value of the stolen carabao. The carabao died of natural causes after it had been recovered from the appellant and while it was in the custody of the Constabulary pending trial. The death occurred without any contributory act from the appellant.
ISSUE:
1. Whether the evidence was sufficient to sustain the conviction. (A question of fact)
2. Whether the appellant should be held civilly liable to indemnify the owner for the value of the carabao, given that it died a natural death while in government custody and not due to any act of the appellant.
RULING:
The Supreme Court affirmed the conviction but modified the penalty.
1. On the Sufficiency of Evidence: The Court held that the evidence was sufficient to sustain the conviction. The credibility of the prosecution witnesses was a matter primarily for the trial court to determine, and the Supreme Court found no reason to interfere with that finding.
2. On Civil Liability: The Court ruled that the appellant is civilly liable to pay the value of the carabao. The general rule is that a person is responsible for the results flowing from his criminal act. When an owner is deprived of possession of property due to a criminal act, the offender is liable for restitution or payment of its value if restitution is impossibleregardless of whether the loss or destruction is due to the offender’s act, the act of another, or any other cause. This rule is supported by Articles 17 and 119 of the Penal Code, which establish that criminal liability gives rise to civil liability comprising restitution, reparation, and indemnification.
DISPOSITIVE PORTION:
The judgment of the trial court was affirmed with modification. One day was added to the penalty, making it four years, ten months, and one day of presidio correccional. The order to pay an indemnity of P80 was sustained. Costs were imposed on the appellant.
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