Case Digest (G.R. No. 47367)
Facts:
En G.R. No. 47367, Jose League solicitó en revisión la sentencia del Tribunal de Apelaciones que había confirmado la condena del Juzgado de Primera Instancia de Laguna, hallándolo culpable de rebelión y imponiéndole una pena indeterminada de dos años, cuatro meses y un día de prisión correccional a ocho años y un día de prisión mayor, además de la multa de P10,000 y las costas. La sentencia se basó en que el acusado era tesorero general del partido Sakdalista, que planeó un levantamiento armado contra el Gobierno para obtener la independencia absoluta antes de finalizar 1935; que el 2 de mayo de 1935 se cortaron líneas telegráficas y telefónicas en Santa Rosa, Laguna, se apagó el alumbrado y se inmovilizaron vehículos, y que varios centenares de sakdalistas armados marcharon para apoderarse del edificio municipal de Santa Rosa, sustraerlo de la obediencia al Gobierno constituido y atacar a los constabularios enviados a restablecer el orden, causando muertos y heridos. Asimismo, Case Digest (G.R. No. 47367)
Facts:
- Proceedings and relief sought in the Supreme Court
- Recurrente Jose League filed for revision of the judgment of the Court of Appeals, which had affirmed the judgment of the Court of First Instance of Laguna.
- The Court of Appeals had held Jose League guilty of rebelion and had imposed the indeterminate penalty of two years, four months and one day of prision correccional to eight years and one day of prision mayor, plus a fine of P10,000, and costs.
- In the Supreme Court, Jose League assailed the qualification of the offense, not the factual participation found by the trial and appellate courts.
- Facts found and relied upon by the Court of Appeals
- Jose League was found to have been the general treasurer of a party called the Sakdalista group.
- The purpose of the Sakdalistas was absolute independence of the Philippines before the end of 1935.
- The Sakdalistas planned an armed uprising in several provinces, particularly Laguna.
- On the night of May 2, 1935, the telegraph and telephone wires connecting the municipality of Santa Rosa, Laguna, with surrounding towns and with Manila were cut.
- On the same night, the electric lights were turned off and the houses were closed.
- Armed persons took positions on the roads to stop the passage of vehicles.
- The armed persons requisitioned passengers and took away the weapons they carried.
- Several hundreds of Sakdalistas, provided with bands, flags, and diverse armaments, marched in a group to seize the municipal building of Santa Rosa and remove it from obedience to the government duly constituted.
- There was a bloody encounter between the Sakdalistas and the constabulary sent to restore order.
- The encounter resulted in deaths and injuries.
- Among the vehicles the Sakdalistas attempted to stop was the automobile of lawyer Feliciano Gomez, who was riding with several members of his family.
- When the automobile did not stop upon the Sakdalistas’ intimidation, it was shot at by the Sakdalistas.
- Jose League was among the armed persons who tried to stop the automobile of Gomez.
- Gomez saw and recognized Jose League because Gomez and League had been childhood companions.
- Damian Hernandez likewise saw the incident and testified that League, from a distance of about ten meters from the vehicle, was armed with a shotgun.
- Jose League fired two shots with his shotgun at Gomez’s automobile, and the projectiles struck the body of the automobile.
- Another vehicle involved was a jitney owned by Ricardo Mendoza.
- Mendoza recognized Jose League among the people who blocked the jitney because League was well illuminated by the headlights of the jitney.
- Jose League’s defense and change of theory on appeal
- Jose League defended himself in the Court of First Instance and in the Court of Appeals.
- He initially attempted to prove a chicanery (coartada), asserting that he was in Manila at the time of the incident.
- Jose League abandoned the coartada on review in the Supreme Court, because both lower courts had declared it lacked credibility for having been clearly ...(Subscriber-Only)
Issues:
- Nature of the offense based on the proven acts
- Whether the acts proven against Jose League and his co-accused constituted rebelion rather than sedicion.
- Effect of territorial extent versus political objective
- Whether the qualification of the offense depended on the greater or lesser extent of territory affected by the a...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)