US V. CARLOS
21 PHIL 553
Accused was charged with larceny or the unlawful use of electric current. He was found guilty.
It is true that electricity is no longer considered as fluid but its manifestations and effects are like those of gas, may be seen and felt. The true test on whether of what is a proper subject of larceny seems to be not whether the subject is corporeal or not but whether it is capable of
appropriation by another than the owner.
Electricity, is a valuable article of merchandise, bought and sold like other personal property and is capable of appropriation by another.
J. MORELAND, DISSENTING:
An electric current is not a tangible thing, a chattel, but is a condition or state on which a thing or chattel finds itself; and that a condition or state cannot be stolen independently of the thing or chattel of which it is a condition or state. That it is chattels, which are subjects of larceny and not
conditions. (Electricity is only energy)