Case Digest (G.R. No. L-17748)
Facts:
In The People of the Philippine Islands vs. Graciano L. Cabrera et al. (43 Phil. 64, G.R. No. 17748, March 4, 1922), the Court of First Instance of Manila tried 77 Philippine Constabulary soldiers for sedition under Act No. 292 of the Philippine Commission and related murder charges. On December 13–15, 1920, after Manila police arrested and allegedly mistreated a soldier’s wife and fatally shot Private Crispin Macasinag, soldiers at Santa Lucia Barracks erupted in a tumultuous uprising seeking revenge. Under cover of darkness, they sawn out window bars, armed themselves with rifles and ammunition, and divided into platoons to fire upon policemen and innocent civilians in Intramuros. The volley at Calle Real and Cabildo killed American Officer Driskill and civilian Jacumin; a streetcar was fired upon, killing Victor de Torres and wounding three passengers; further attacks killed Captain Wichman, Policeman Saplala, Patrolmen Trogue and Sison, and Policarpio, while others were wounCase Digest (G.R. No. L-17748)
Facts:
- Background
- On December 13, 1920, Manila policemen arrested a woman belonging to a Constabulary soldier’s household at Santa Lucia Barracks, sparking resentment among Constabulary troops.
- On December 14, 1920, Constabulary Private Crispin Macasinag was mortally wounded in a street encounter with Police Corporal Artemio Mojica, deepening the soldiers’ desire for revenge.
- Uprising on December 15–16, 1920
- A rumor that Mojica remained on duty and Macasinag had died led Corporal Ingles and others to have Private Torio allow a mass escape through a sawed‐out window. Armed groups formed to attack the city police.
- Multiple volleys were fired by Constabulary squads at various Intramuros locations, killing American Patrolman Driskill and field clerk Jacumin; passengers in a streetcar; Captain Wichman and Patrolman Saplala; Patrolmen Trogue and Sison; and mortally wounding others, including Policarpio.
- Investigation and Confessions
- On December 16, Colonel Lucien R. Sweet assembled 180 soldiers, separated them by company, and invited participants to step forward. Seventy-seven admitted leaving the barracks and taking part in the shooting.
- A uniform questionnaire was administered, yielding 77 written statements (Exhibits C–C-76), each sworn and witnessed, including that of Sergeant Graciano L. Cabrera, detailing motives, actions, and arms used.
- Trial and Sentencing
- Two informations charged the defendants with sedition (Act No. 292) and, separately, with murder and serious physical injuries; pleas shifted from guilty to not guilty.
- The court admitted the confessions over defense objections, found conspiracy and sedition proved beyond reasonable doubt, and sentenced each defendant to the maximum ten years’ imprisonment, with fines up to ₱10,000 imposed on corporals and sergeants, and cost allocations.
Issues:
- Whether Exhibits C–C-76 (the 77 confessions) were freely and voluntarily made and thus admissible.
- Whether a conspiracy among the accused existed to commit sedition.
- Whether the facts support conviction for sedition under section 5, paragraph 3, of Act No. 292.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)