G.R. No. L-6368 / February 21, 1911
THE UNITED STATES, plaintiff-appellee, vs. BONIFACIO DIVINO, defendant-appellant.

FACTS

On the night of July 3 or 4, 1907, two unidentified armed men forcibly took a carabao from Miguel Lagamia, a servant of Felix Atacador. On September 4, 1907, the same carabao was found in the possession of Leoncio San Gabriel, a cropper working for the accused, Bonifacio Divino. San Gabriel stated that Divino had given him the carabao for farm work. Neither San Gabriel nor Divino possessed the legal documents required to prove ownership of the carabao. Consequently, provincial officials seized the carabao. While the carabao was being used in public works, the owner, Felix Atacador, recognized it by its brand and unique physical marks. Atacador presented his ownership documents, and after verification by the provincial governor, the carabao was returned to him. The prosecution established the identity of the stolen carabao and its recent possession by the accused, who offered no explanation for such possession.

ISSUE

Is the conviction of the accused for robbery valid based solely on his recent possession of the stolen property without a satisfactory explanation?

RULING

Yes. The Supreme Court affirmed the conviction. The Court applied the doctrine that recent, unexplained possession of stolen property justifies conviction for robbery. The identity of the carabao as the one stolen from Atacador was conclusively established by the owner’s recognition and the verification of its marks. The accused, found in possession of the carabao shortly after the robbery without the required ownership documents and without offering any explanation, was properly convicted under the precedent set in U.S. vs. Soriano and U.S. vs. Santillan. The judgment of the Court of First Instance was affirmed.