Teodoro Mariano y Lingat (Alias Pañgan) v. People

Summary

Teodoro Mariano was charged with qualified theft after taking P10.20 from his benefactor's trunk while staying at the barbershop out of charity. The Court of First Instance convicted him of theft qualified by grave abuse of confidence and imposed additional penalty for habitual delinquency. The Court of Appeals reduced the penalty, finding no grave abuse of confidence. The Supreme Court reversed, holding that when appellant was charitably allowed to stay in the barbershop, this created confidence which was gravely abused when he stole money. The Court rejected arguments that returning the money negated the crime and restored the original sentence. This case establishes that charitable shelter creates a relationship of confidence that, when violated through theft, qualifies the crime under aggravating circumstances.