Case Digest (G.R. No. 36277)
Facts:
The People of the Philippine Islands v. Crisanto Evangelista and Abelardo Ramos, G.R. No. 36277, October 26, 1932, the Supreme Court En Banc, Ostrand, J., writing for the Court.The People of the Philippine Islands (plaintiff and appellee) prosecuted Crisanto Evangelista and Abelardo Ramos (defendants and appellants) in the Court of First Instance of Manila for violating Section 8 of Act No. 292, as amended. The trial court convicted each defendant, sentencing them to six months' imprisonment, a fine of P400 (with subsidiary imprisonment for insolvency), and to pay one-half of the costs. The defendants appealed to the Supreme Court.
The factual background was that on May 1, 1931 a planned Communist parade in the municipality of Caloocan (within two and one-half miles of Manila) proceeded despite the revocation of a permit. A Constabulary officer and soldiers arrived to prevent the parade. Evangelista, described as the apparent leader of those assembled, spoke briefly after a conference with the Constabulary officer; he raised his fist and told the crowd that although the municipal president had allowed the parade, the permit had been revoked and that "the big ones are persecuting and oppressing us, who are small," prompting the crowd to shout "mabuhay" and later "Let us fight them." Ramos, among the crowd, shouted "Let us fight them until death."
The Constabulary arrested Evangelista and Ramos after the officer stopped Evangelista during his speech. The crowd advanced in an attempt to wrest Evangelista from the officers; the soldiers used a water pump to disperse and restore order. A permit and its revocation were found on Evangelista's person. At trial the appellants denied making the quoted utterances and claimed the assembly was peaceful, but the trial court found the prosecution witnesses credible. The ...(Pro-only)
Issues:
- Did the utterances and conduct of Evangelista and Ramos constitute sedition under Section 8 of Act No. 292, as amended?
- Should the trial court’s factual findings be disturbed o...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)