Case Digest (G.R. No. L-11870) Core Legal Reasoning Model
Facts:
On November 23, 1953, the Provincial Fiscal of Rizal filed an information in the Court of First Instance of Rizal charging Fermin Tolentino, Benito Cruz, and Paterno Cruz with the “complex crime of rebellion, with multiple murder, robberies and arsons,” punishable by life imprisonment. The information alleged that from May 28, 1946, continuing through subsequent years, the accused as officers and members of the Hukbong Mapagpalaya ng Bayan (HMB) conspired to overthrow the Government of the Republic of the Philippines. Specifically, on March 20, 1951, in Antipolo, Rizal, Benito Cruz, commanding armed Huks including his brother Paterno, raided the Hardie Farm, looted P5,000.00 worth of property, tied and executed John D. Hardie, Donald Capuano, and Mrs. Irene Hardie. Both brothers were captured on July 26, 1951, in Montalban, where they executed affidavits (Exhibits V, X, AA, Y) admitting Huk membership and command, later recanting under claim of duress. Fermin Tolentino was appr
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Case Digest (G.R. No. L-11870) Expanded Legal Reasoning Model
Facts:
- Charge and Information
- On November 23, 1953, the Provincial Fiscal of Rizal filed an information against appellants Benito Cruz, Paterno Cruz, and Fermin Tolentino, together with other alleged Huk affiliates, for the complex crime of rebellion with murder, robbery, and arson.
- Appellants were accused of conspiring as Communist Party members and Hukbong Mapagpalaya ng Bayan (HMB) officers to overthrow the Philippine Government by armed uprising.
- Alleged Rebellious Acts
- March 20, 1951 (Antipolo, Rizal): Raid on the Hardie Farm by Benito Cruz (Commander Saling), Paterno Cruz, and armed Huks; looting of valuables (typewriter, radio, jewelry, clothing) and the murders of John D. Hardie, Donald Capuano, and Irene W. Hardie.
- March 21, 1951 (Pililla, Rizal): Armed clash between HMB’s FC-32, led by “Comdr. Robert,” and Co. D, 14th BCT, AFP.
- April 21, 1951 (Moron, Bataan): Attack by FC-25 under Fermin Tolentino against an AFP detachment, causing deaths and injuries; similar attack in Hermosa, Bataan, later the same year.
- November 15, 1952 (San Mateo, Rizal): Encounter between FC-46, RECO-4 Huks led by Domingo dela Torre and elements of the 7th BCT, AFP, and Montalban Civilian Commando.
- Various dates and places (Tanay, Rizal; Bongabong, Nueva Ecija; Tarlac; Sta. Cruz, Laguna): Multiple ambushes, assassinations (including Mrs. Aurora A. Quezon), arsons, and large-scale raids for supplies, culminating in widespread disorder and fear.
- Apprehension and Evidence
- July 26, 1951: Capture of Benito and Paterno Cruz in San Rafael, Montalban; execution of affidavits (Exhs. V, X, AA, Y) admitting Huk affiliation and leadership roles.
- Confessions by Fermin Tolentino (Exhs. BB, OO, PP, HH, II, JJ) acknowledging his rank as Commander of FC-25 (“Commander Caviteno”) and detailing HMB operations.
- Testimonies of former Huk members (Nicolas Lipunan, Tomas Timbresa, Onofre de Jesusa, Pablo Guinto) and military officers corroborating appellants’ participation in raids and leadership roles.
- Appellants’ denials of duress, with defense witnesses attesting to their peaceful character; trial court found no credible evidence of coercion.
Issues:
- Whether the acts imputed to appellants constitute the crime of rebellion with robbery, homicide, and arson or only simple rebellion.
- Whether the life imprisonment penalties imposed should stand or be reduced under the provisions governing simple rebellion and commanding officers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)