G.R. No. L-1360, December 4, 1903
THE UNITED STATES, complainant-appellee, vs. ADAM SMITH, defendant-appellant.

FACTS:
The defendant, Adam Smith, was charged with the crime of robbery. The complaint alleged that in December 1902, in the house of the acting justice of the peace of Albay, he took money valued at $600 from Pedro Ralla and Josefa Garcia through violence and intimidation. The evidence presented at trial, however, established that the act occurred on or about January 8, 1903. On that date, the defendant, representing himself as a detective, summoned Ralla and Garcia to the justice’s house. He falsely claimed to have authority to arrest them and threatened them with imprisonment in Manila unless they paid him money. Through these threats and intimidation, the defendant extorted and received from the victims the sum of $700 (Mexican). The defendant admitted receiving the money but claimed it was given to him as a bribe to secure the release of another individual, Isabelo Madera, and that he intended to use it as evidence in a separate case. The trial court found him guilty of robbery and sentenced him to three years and eight months of presidio correccional.

ISSUE:

2. Whether the acts committed by the defendant constitute the crime of robbery or the crime of estafa (swindling).

RULING:
The Supreme Court affirmed the conviction.

2. On the nature of the crime: The defendant’s acts constitute robbery, not estafa. The Court, citing Spanish jurisprudence, distinguished between the two crimes. Estafa is committed through deceit or cunning, where the victim’s will remains free, though influenced. Robbery with intimidation is committed by employing threats of an impending evil to produce intimidation and compel the victim to part with their property. Here, the defendant obtained the money through threats of arrest and imprisonment, which constituted intimidation, not mere deceit. Therefore, the crime is properly classified as robbery.

The decision of the lower court was affirmed.