Case Digest (G.R. No. 976) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The United States vs. Maximo Abad (G.R. No. 976, October 22, 1902), the United States, as complainant and appellee, prosecuted Maximo Abad, a former Filipino insurgent officer, for violation of an oath of allegiance taken before a United States Army officer upon his surrender in April 1901. Under section 14 of Act No. 292 (the Revised Penal Code enacted by the U.S. Philippine Commission), anyone who, after swearing to “recognize or accept the supreme authority of the United States” or to “maintain true faith and allegiance thereto,” violates that oath is punishable by fine or imprisonment. Abad, having denied knowledge of concealed rifles at the time of his surrender, was tried and convicted by the Court of First Instance of Manila for breaching his oath. He then invoked the President’s proclamation of amnesty, which pardoned “offenses of treason and sedition,” claiming that his offense fell within its scope. The United States government appealed Case Digest (G.R. No. 976) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Statutory Charge and Penalty
- The defendant was charged under section 14 of Act No. 292 of the Philippine Commission, which punishes any person who, having taken an oath to recognize or accept U.S. sovereignty and to obey its laws, later violates that oath.
- The penalty prescribed is a fine not exceeding \$2,000, or imprisonment up to ten years, or both.
- Defendant’s Background and Conduct
- Maximo Abad is a former insurgent officer who surrendered in April 1901 and took the prescribed oath of allegiance.
- At trial, he was found to have denied to a U.S. Army officer the existence and location of certain rifles he had concealed at the time of his surrender, conduct deemed a violation of his oath.
- Amnesty Proclamation Context
- The President’s proclamation of amnesty embraced “offenses of treason and sedition” as the first class of offenses to be pardoned.
- There was no evidence that Abad’s act was committed pursuant to orders of insurrectionary authorities or grew out of internal political feuds among Filipinos or between Filipinos and Spaniards.
Issues:
- Whether a violation of the oath of allegiance under section 14 of Act No. 292 falls within the scope of “offenses of treason and sedition” in the presidential amnesty proclamation.
- Whether the technical legal definitions of treason and sedition in Act No. 292 exclude the offense of oath violation from amnesty.
- Whether the proclamation’s general language must be construed liberally to effectuate its beneficent purpose and include all political offenses defined in Act No. 292.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)