- Petitioner
- People of the Philippines, petitioner,
- Respondent
- Lilibeth Romero y Dulaca a.k.a. “Beth”, respondent
- Citation
- G.R. No. 2323
- Court
- Supreme Court
- Decided
- January 31, 1906
Theft of a watch valued at $50 Mexican currency
Summary
This 1906 criminal case involved Natividad Pareja who was convicted of theft of a watch worth $50 Mexican currency belonging to Gregorio Gutay. The trial court sentenced her to four months imprisonment under Article 518, paragraph 4 of the Penal Code, plus costs and restitution or subsidiary imprisonment. On appeal, the Supreme Court En Banc affirmed the conviction, finding the evidence sufficient and no procedicial errors. However, the Court modified the sentence to explicitly require restoration of the stolen watch to the owner or payment of its value if restoration is impossible. This case demonstrates the application of theft provisions under the Spanish-era Penal Code and the principle of restitution in criminal cases during the early American colonial period in the Philippines.
Focus of dispute
Theft of a watch valued at $50 Mexican currency
Legal facts
Natividad Pareja was accused of stealing a watch worth $50 Mexican currency belonging to Gregorio Gutay. The trial court convicted her of theft and sentenced her to four months imprisonment (arresto mayor in its medium degree), payment of costs, and restitution to the victim or subsidiary imprisonment.
Judgement and reasoning
Supreme Court (En Banc): Affirmed the conviction finding that the trial court's findings were fully sustained by the evidence and no error prejudicial to the accused's rights occurred. Modified the sentence to specifically include direction for the accused to restore the stolen watch to its owner or pay its value if restoration cannot be complied with.
Trial Court: Convicted Natividad Pareja of theft of a watch valued at $50 Mexican currency, sentenced her to four months imprisonment (arresto mayor in medium degree), payment of costs, and restitution or subsidiary imprisonment under Article 50 of the Penal Code.