This aligns with the doctrine in People v. Avila

Summary

This landmark 1923 Supreme Court case established the principle that criminal appropriation of found property constitutes theft rather than estafa under Philippine criminal law. Defendant Clemente Avila, a municipal policeman, was entrusted by a carretela driver with a purse containing P4,500 in valuables to return to its owner, Lucio Pilares, but instead appropriated it for himself. The Supreme Court affirmed the theft conviction, holding that one who receives lost property from the actual finder assumes the same legal position as the finder and can be guilty of theft under Article 517(2) of the Penal Code. The Court provided extensive historical and comparative legal analysis, tracing theft concepts from Roman law through Spanish and common law traditions, establishing important precedent for the interpretation of theft provisions in Philippine criminal law.