G.R. No. L-4974-78 - People vs. Lava

The People of the Philippines filed identical informations in five Criminal Cases (Nos. 14071, 14082, 14270, 14315, 14344) charging 31 defendants with the complex crime of rebellion “with murders and arsons” under Articles 134–136 and Article 48 of the Revised Penal Code.
The informations alleged that beginning May 6, 1946, high-ranking officers and members of the Communist Party (PKP) and its armed wing, Hukbong Mapagpalaya ng Bayan (HMB), conspired to overthrow the Government by armed raids, ambushes, robberies, murders, arsons and other acts across Luzon and the Visayas.

Motions to quash the informations and petitions for bail were denied by the Court of First Instance of Manila on November 1, 1950.
With all defendants’ conformity, the five cases were consolidated for joint trial. Evidence taken in the first two cases was reproduced in the latter three by agreement of parties.
During trial, the prosecution moved for—and was granted—dismissal of two defendants for insufficiency of evidence. A total of 26 defendants were ultimately convicted in the joint decision dated May 11, 1951; five were acquitted.

The trial court found various defendants guilty as principals or accomplices of “rebellion with multiple murder, arsons, and robberies,” imposing penalties ranging from arresto mayor to death.
Of the 26 convicted, 18 appealed to this Court (G.R. Nos. L-4974 to L-4978). Appeals of several minors and deceased defendants were resolved or withdrawn; five remaining accused were acquitted by trial court.
Original documentary exhibits were destroyed in a 1958 fire at Camp Crame. By order of this Court, photostatic and typewritten copies were admitted after reconstitution proceedings under Act 3110, and the appeals were submitted for decision in 1963.

Whether rebellion may be prosecuted as a complex crime with murder, arson, robbery, and other common crimes under Article 48 of the Revised Penal Code.
Whether the informations are duplicitous or charge multiple offenses in violation of Rules 106/117, Rule 117.
Whether venue in Manila was proper though substantive acts occurred elsewhere.
Whether reconstituted documentary exhibits (photostats, microfilms, certified copies) were admissible after destruction of originals.

Sufficiency of evidence to establish each appellant’s role (principal vs. accomplice vs. conspiracy).
Constitutional and procedural questions concerning search warrants, detention, and trial preparation time.
Claims of coercion or improper identification of handwriting and exhibits.