GR L 4146; (March, 1908) (Digest)
FACTS:
Petra de Guzman (accused-appellant) was charged with the robbery of 21 cavanes of palay. The palay belonged to the estate of her first cousin, Susana de Guzman. Susana had executed a will leaving her property to the son of a niece. Upon Susana’s death, Petra de Guzman contested the will, believing she had a right to inherit. In this context, Petra de Guzman went to the warehouse where the palay was stored, broke open the padlocks, and took the rice. She did so publicly, in the presence of the warehouse keeper and the barrio lieutenant, asserting that “it was her own property” and that no one could prevent her. She genuinely believed in good faith that she was the lawful heir, a belief the court attributed partly to her lack of education. Furthermore, Petra de Guzman testified, and it was uncontradicted, that she removed the rice to pay the land tax due for Susana’s land, which she subsequently did. The Court of First Instance found her guilty of robbery.
ISSUE:
Whether Petra de Guzman is guilty of robbery, given her good faith belief of heirship and her intent to use the proceeds of the palay to pay the estate’s tax rather than for personal gain.
RULING:
The Supreme Court, in G.R. No. L-4146 on March 13, 1908, reversed the judgment of the Court of First Instance and acquitted Petra de Guzman. The Court ruled that the crime of robbery, under Article 502 of the Penal Code, requires the essential requisite of “intent to obtain gain” (animo lucrandi). In this case, Petra de Guzman acted in good faith, genuinely believing she had a right to the property. More critically, she did not intend to obtain personal gain, but rather used the proceeds from the palay to settle a necessary and unavoidable obligation of the estate (the land tax). Since the intent to obtain gain was absent, she could not be held guilty of robbery. The Court further noted that any disputes regarding her intervention in the estate should be resolved through a civil action.
