- Petitioner
- The United States
- Respondent
- Emiliano Aronce
- Citation
- G.R. No. 4782
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Torres, J.
- Decided
- December 19, 1908
Whether the taking of personal property from an unlocked wardrobe constitutes theft or robbery under the Penal Code
Summary
The Supreme Court reversed a robbery conviction to theft in this 1908 case involving Emiliano Aronce, who stole a watch and necklace from an unlocked wardrobe while the victim slept. The Court distinguished theft from robbery, holding that opening an unlocked wardrobe without force or violence constitutes theft under Article 517, not robbery under Article 508 of the Penal Code. Despite the charge reduction, the Court imposed a heavier sentence of four years, two months, and one day of presidio correccional due to Aronce's recidivism, having been convicted nine times previously including six theft-related offenses. The case establishes important precedent on the distinction between theft and robbery based on the degree of force employed against property.