Facts:
On July 12, 1982, Constancio Ordonio was indicted for cattle rustling in Negros Oriental, Philippines, accused of stealing a calf from Anastacio Pajunar on January 5, 1982. Pajunar noticed the calf’s absence the following day and, after searching, confronted Ordonio, who denied seeing the calf. Pajunar eventually found the calf tied near Ordonio’s house, leading to an altercation where Ordonio claimed the calf was his brother’s.
Following the incident, Pajunar sought assistance from local authorities, resulting in the calf being placed in official custody. Ordonio and his wife then admitted to Pajunar’s ownership of the calf, leading to its return. The trial court convicted Ordonio of cattle rustling, relying on his actions upon the calf’s discovery and inconsistent defenses. Despite a motion for a new trial based on new evidence, the conviction was affirmed by both the trial court and the Court of Appeals on appeal. Ordonio’s subsequent appeal to the Supreme Court centered on alleged factual misapprehensions and evidentiary issues.
Issues:
1. Whether the actuations of Ordonio upon discovery of the calf constitute cattle rustling.
2. Whether the appellate court erred in affirming Ordonio’s conviction based on alleged misapprehension of facts and evidence.
Court’s Decision:
The Supreme Court affirmed the decisions of both lower courts, concluding that Ordonio’s repeated denials of seeing the calf, along with his claim that the calf belonged to his brother even though it was proven to belong to Pajunar, constituted cattle rustling as defined under Presidential Decree No. 533. The Court held that intent to gain could be inferred from Ordonio’s unwillingness to return the calf to its rightful owner and his attempts to assert ownership over it.
Doctrine:
The decision illustrates the interpretation of “cattle rustling” under Presidential Decree No. 533 as taking away livestock by any means without the owner’s consent, including scenarios where the taker knows the livestock does not belong to them. Intent to gain may be inferred from the refusal to return lost property.
Class Notes:
– Cattle Rustling: As defined under PD 533, it is the unauthorized taking away of livestock by any means, including for gain and whether or not violence or intimidation is used.
– Intent to Gain: In theft-related offenses, intent to gain can be inferred from the defendant’s actions that demonstrate a refusal to return property known not to belong to them.
– Factual Findings: The factual findings of the lower courts, when affirmed by the appellate court, are conclusive and cannot be reviewed except under certain exceptions.
– Legal Appeals: In petitions under Rule 45 of the Rules of Court, review is limited to errors of law, not factual issues, unless there is a misapprehension of facts.
Historical Background:
The case of Ordonio v. Court of Appeals and People of the Philippines reflects the broader legal and social issues surrounding livestock theft in rural communities, highlighting the responsibility of individuals to return lost property and the legal mechanisms in place to protect property rights. The decision reaffirmed the stringent interpretation of cattle rustling laws, aiming to deter theft and ensure accountability.
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