GR L 3968; (March, 1908) (Digest)
March 4, 2026GR L 3904; (March, 1908) (Digest)
March 4, 2026G.R. No. L-3975
THE UNITED STATES, plaintiff-appellee, vs. ANGEL MARIN, defendant-appellant.
March 21, 1908
FACTS:
On April 27, 1906, Angel Marin received a watch from Maximo K. Engel under an agreement to raffle it, pay Engel P150 from the proceeds, and return the watch nightly until the sum was paid. On May 3, 1906, Marin pawned the watch to Jose Atienza for P52, falsely claiming it as his property. The following day, Marin left Bacolod. Engel subsequently filed a complaint for estafa. Upon learning of the complaint, Marin returned, redeemed the watch, and surrendered it to the justice of the peace, maintaining that he had purchased it from Engel.
Marin’s defense was that on the morning of May 3, before pawning the watch, he returned it to Engel, informing him he could not raffle it, and Engel then sold it to him on credit for P125, payable by the end of May. Marin presented three witnesses to corroborate this: Felipe Gepulco (who claimed to witness the sale), Jose Atienza (who testified Engel offered to pay the pawn amount, stating he had sold the watch on credit), and Francisco Geolingo (who claimed Engel told him he sold a watch to Marin on credit and had to wait for payment).
The trial judge disbelieved the defense’s witnesses and convicted Marin of estafa. The judge cited Gepulco’s errors in describing Engel’s name, nationality, and facial features, Geolingo’s inability to recall the exact date of a conversation, and the inherent improbability of Engel, a merchant desiring to leave town, selling the watch on credit for a lower price (P125 vs P150 expected from raffle) to someone he had previously imposed strict conditions on due to lack of confidence.
ISSUE:
Was the defendant’s guilt of estafa proven beyond a reasonable doubt, given the trial court’s rejection of his defense?
RULING:
The Supreme Court reversed the conviction and acquitted Angel Marin.
The Court conceded that the defendant’s story and his witnesses’ testimony might be “improbable” and bear “an air of improbability.” However, the Court emphasized that improbability alone is not sufficient to establish falsity beyond a reasonable doubt, especially when the prosecution offered no direct evidence to contradict the defense’s account (Engel, the owner, did not testify and was out of the province at the time of trial).
The Court found the trial judge’s reasons for discrediting the defense witnesses to be inconclusive. It noted that Gepulco’s mistakes regarding Engel’s nationality and facial hair were understandable given that he had seen Engel only once, nearly eight months before the trial. Similarly, Geolingo’s inability to recall the precise date of a casual conversation several months prior was not surprising. The Court also held that a sale on credit under the conditions and at the price alleged by the defense, while “extraordinary,” did not conclusively render the entire story false beyond a reasonable doubt.
Since the falsity of the defense’s claim of purchase was not proven beyond a reasonable doubt, the judgment of conviction could not be sustained. The Court found that reasonable doubt existed, necessitating Marin’s acquittal.

