G.R. No. L-9444; October 29, 1914
THE UNITED STATES, plaintiff-appellee, vs. SOFRONIO DE LA CRUZ, defendant-appellant.

FACTS:
Sofronio de la Cruz was charged with the crime of threats under Article 494 of the Penal Code. The prosecution alleged that he threatened Dolores Coronel, a 70-year-old woman, through a letter (Exhibit A) demanding P500 and threatening her with death or the burning of her house if she failed to comply. The letter was found in the fence around her house by Rafaela Coronel and later given to Agustin Coronel, who read it to Dolores Coronel, causing her distress. The municipal president, upon investigation, found the defendant under arrest by the Constabulary. A search of the defendant revealed an envelope (Exhibit B) in his pocketbook bearing the name “Dolores Coronel.” Handwriting comparison showed that the writing on Exhibit B was similar to that on the threatening letter (Exhibit A) and another letter (Exhibit C) addressed to a different person, Andres Valenzuela. The defendant claimed that Tito Coronel wrote the name on Exhibit B, but a comparison of Tito Coronel’s handwriting in court disproved this. The Court of First Instance of Pampanga convicted the defendant and sentenced him to four years, two months, and one day of prision correccional, with accessories, credit for half his preventive detention, and costs.

ISSUE:
Whether the trial court erred in denying the defendant’s motion to dismiss after the prosecution rested its case on the ground of insufficient evidence.

RULING:
The Supreme Court affirmed the conviction. The Court held that the trial court did not err in denying the motion to dismiss. Citing United States v. Abaroa, the Court explained that a trial court should not dismiss a case after the prosecution rests based on perceived insufficiency of evidence; instead, it should require the defendant to present evidence. This practice ensures that if an appellate court later finds the prosecution’s evidence sufficient, the defendant would not be convicted without having been heard. The Court found the prosecution’s evidence sufficient, particularly the handwriting comparison between Exhibits A, B, and C, which established that the defendant authored the threatening letter. The defense’s attempt to attribute the writing to Tito Coronel failed. The defendant was thus guilty under Article 494(1) of the Penal Code. The penalty for threats is two degrees lower than the penalty for the crime threatened (homicide, punishable by reclusion temporal). Applying the penalty scale, the penalty two degrees lower is prision correccional in its maximum degree (4 years, 2 months, and 1 day to 6 years). The imposed penalty of 4 years, 2 months, and 1 day was within the correct range and affirmed.