G.R. No. 36277 - People vs. Evangelista

The People of the Philippine Islands charged Crisanto Evangelista and Abelardo Ramos with violating Section 8 of Act No. 292, as amended (sedition).
The Court of First Instance of Manila found both defendants guilty, sentencing each to six months’ imprisonment, a fine of ₱400 (with subsidiary imprisonment upon insolvency), and payment of one-half the costs. The defendants appealed.

A communist parade was planned in Caloocan (within 2½ miles of Manila). A municipal permit was issued by President Aquino but later revoked.
A Constabulary officer and soldiers arrived to enforce the revocation. Evangelista, acting as leader, discussed the permit with the officer and was allowed to address the crowd.
Instead of ordering dispersal, Evangelista denounced the revocation as persecution of the “small,” raised his fist, and incited opposition to authorities. Ramos shouted “Let us fight them until death.”
The crowd attempted to seize Evangelista from the Constabulary and continue the parade; soldiers used a water pump to disperse them.
On Evangelista’s person were found the original permit and its revocation.

Both appellants denied making the incriminated statements and claimed the assemblage was peaceful.
The trial court credited the prosecution’s evidence, found the utterances seditious, and noted the actual advance of the crowd against law enforcement. The appellants did not furnish reasons to overturn those findings.

Whether the statements and conduct of Evangelista and Ramos constituted sedition under Section 8 of Act No. 292, as amended.
Whether a mere public disorder (as argued by defense under United States v. Apurado) can be equated with sedition.