G.R. No. 36429 - People vs. Feleo

On the evening of December 7, 1930, a public meeting was held in the barrio of Tambo, San Leonardo, Nueva Ecija, where the communists convened.
An estimated audience of about one hundred persons attended the meeting.
The meeting was notable for the presence of members of the Philippine Constabulary who were acting on instructions from their headquarters.

Juan Feleo, then a leader of the communists in Nueva Ecija, delivered a speech before the gathered audience.
His remarks were recorded in longhand by Lieutenant Arambulo and Sergeant Caba, who identified parts of the speech as seditious.
The speech, when translated into English, contained language urging actions such as:

Imitating French soldiers by directing weapons not at enemies but at their own chiefs.
Inciting the constabulary to use their arms against the American government rather than against communist elements.
Expressing hope that the Constabulary men and scouts would desert to side with the communists (“the reds”) and support the revolutionary cause.

The speech also highlighted perceived injustices against constabulary privates, emphasizing their low salaries contrasted with the high compensations of their commanding officers.
It was suggested that if the soldiers united in rebellion, significant changes would follow:

The downfall of the provincial commander (specifically mentioning Captain S. F. Cacdac).
The prospect of the communists taking over haciendas, the railroad company, and other assets.

Such language was argued by the government to constitute a call to insurrection and sedition.

The trial court, sitting as part of the Court of First Instance of Nueva Ecija, found Juan Feleo guilty of sedition or inciting seditious acts under section 8 of Act No. 292 of the Philippine Commission.
In reaching its judgment, the trial court placed weight on the testimonies of the constabulary officers who, during the meeting, recorded the potentially seditious phrases in the course of their duty.
The defense contended that the words in question were mild and inoffensive; however, the credibility of the prosecution’s witnesses was upheld based on:

Whether the statutory provision under which Feleo was convicted (section 8 of Act No. 292) contravenes the constitutional guarantee contained in section 3 of the Jones Law, which declares that no law shall be passed abridging the freedom of speech or of the press.

Whether the language used by Juan Feleo in his speech, in view of its content and implications, qualifies as seditious.
Whether such seditious utterances fall within the limits of permissible expression under the constitutional free speech protections, or whether they incur punishment under the doctrine of state police power meant to preserve public order.