G.R. No. L-6469 / March 18, 1911
THE UNITED STATES, plaintiff-appellee, vs. EUSTAQUIO SIMBAHAN, defendant-appellant.

FACTS

On May 18, 1910, Pedro Carandang discovered that a female carabao entrusted to him had disappeared from where he tied it behind his house. After days of searching, Pedro, along with Prudencia Carandang and Ciriaco Carandang, met the defendant, Eustaquio Simbahan. When asked for help in locating the animal, Simbahan initially denied any knowledge. After a private conversation with Prudencia, he agreed to reveal the carabao’s location on the condition that he be paid P50. The parties agreed to meet again at midnight at a designated isolated place. At the meeting, after receiving the P50, Simbahan pointed to a spot west of a small forest, stating, “There it is.” The group found the carabao tied about four brazas away at the indicated location. Simbahan was subsequently arrested.

ISSUE

Whether the facts constitute sufficient “possession” of the stolen carabao by the defendant to warrant his conviction for larceny based on the presumption that the possessor of stolen property is the author of the crime.

RULING

Yes. The Supreme Court affirmed the conviction. The Court held that the legal concept of “possession” is not limited to manual touch or personal custody. It includes situations where a person deposits stolen property in a place of concealment. In this case, the defendant’s actionsknowing the exact hidden location of the stolen carabao, revealing it only upon payment of P50 at midnight in an isolated spot, and immediately disappearingconclusively demonstrated his possession of the stolen animal. In the absence of any satisfactory explanation from the defendant, this possession gave rise to the presumption that he was the author of the larceny. The conviction and sentence imposed by the trial court were therefore upheld.