Title
People vs. Cabrera
Case
G.R. No. L-17748
Decision Date
Mar 4, 1922
In 1920, Constabulary soldiers, seeking revenge for a comrade's death, attacked Manila police, killing several. Convicted of sedition, their confessions were deemed voluntary, proving conspiracy under Act No. 292.
A

Case 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)

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