G. R. No. 3422. August 03, 1907 (Case Brief / Digest)

**Title:** The United States v. Manuel Samonte

**Facts:** The case revolves around the robbery committed by Manuel Samonte against Nicolasa Sumbingco on the night of December 30, 1905, in Manila, Philippines. Samonte was accused of forcibly taking 38 pesos from Sumbingco with the use of violence and intimidation. The Court of First Instance of Manila convicted Samonte on March 26, 1906, sentencing him to six years ten months and one day of presidio mayor, among other penalties. Samonte appealed the judgment.

The sequence of events leading to Samonte’s conviction began when Sumbingco, returning from the Pasay race track in the company of Feliciano Tolentino, was robbed by Samonte. Despite immediate attempts to pursue Samonte, only his hat and a single coin were recovered from the scene. The police were notified, and Samonte was arrested six days after the incident.

Samonte’s defense was that he was in a relationship with Sumbingco and fled after a dispute that evening, unrelated to robbery. This claim was supported by witnesses that purportedly saw Samonte and Sumbingco together shortly before the incident and heard expressions of their relationship dispute. However, the prosecution’s version of events was bolstered by multiple eyewitnesses, including an American who partially witnessed the assault from his home, thereby leading to Samonte’s conviction.


1. Whether the act committed by Manuel Samonte constitutes robbery under article 503 of the Penal Code.
2. Whether the defense provided by Samonte and his witnesses was credible enough to counter the prosecution’s evidence.
3. The applicability of aggravating circumstances in determining the penalty.

**Court’s Decision:**

The Supreme Court affirmed the judgment of the Court of First Instance, finding Manuel Samonte guilty of robbery. The Court concluded that the facts established Samonte’s use of force and violence to commit the robbery, thus fulfilling the legal definition under article 503 of the Penal Code. The Court found the defense’s narrative and witnesses less credible than those of the prosecution, placing emphasis on the immediate identification of Samonte by Sumbingco and Tolentino, the discovery of Samonte’s hat at the crime scene, and the corroboration by other eyewitnesses.

Regarding aggravating circumstances, the Supreme Court clarified that nocturnity was correctly considered an aggravating factor because Samonte exploited the night to facilitate the robbery. However, it rejected the application of other proposed aggravating circumstances, aligning with precedent to dismiss those not expressly applicable to crimes against property or not meeting the legal relationship requirements stipulated by the Penal Code.


The case reiterates the principle that for an act to constitute robbery, it must be proved that property was taken with intent to gain, using force or violence against persons. Additionally, it clarifies the application of aggravating circumstances in determining penalties for criminal acts, specifically regarding robbery.

**Class Notes:**

– **Key Elements for Robbery:** Intent to gain, use of force or violence, unlawful taking of property.
– **Aggravating Circumstances:** When assessing penalties, nocturnity can aggravate the circumstance if it facilitates the commission of the crime. Relationship-based aggravating circumstances require a legal or blood relationship specified by law.
– **Credibility of Witnesses:** The Court gives weight to the consistency, directness, and corroboration of witness testimony, especially in cases involving immediate identification and pursuit of the perpetrator.

**Historical Background:** The case exemplifies the judicial process in early 20th century Philippine legal system under American rule, showcasing the interaction between local criminal practices and the inherited Spanish Penal Code. It reflects the period’s emphasis on corroborative witness testimony and the interpretation of legal doctrines consistent with Spanish jurisprudence adapted to Philippine context.


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