Case Digest (G.R. No. 8722)
Facts:
United States v. Buenaventura Balcorta, G.R. No. 8722. September 10, 1913, the Supreme Court, Trent, J., writing for the Court. The United States, plaintiff and appellee, prosecuted Buenaventura Balcorta, defendant and appellant, for interrupting and disturbing a religious service. The Court of First Instance of Nueva Ecija convicted Balcorta under Article 223 of the Penal Code and sentenced him to three years, six months, and twenty-one days of prision correccional and a fine of 625 pesetas, with accessory penalties.The facts as found show that Balcorta entered a private house where between ten and twenty persons were holding services of the Methodist Episcopal Church; he carried a club and threatened the assemblage, thereby interrupting or disturbing the divine service. On appeal to the Supreme Court (the present proceeding), Balcorta contended that the record did not sustain a conviction under Article 223 but, if anything, supported only a conviction under paragraph 1 of Article 571 of the Penal Code for disturbing a religious ceremony.
The Court reviewed the historical and legal background of the pertinent Penal Code provisions, including the effect of the Spanish constitutions (1869 and 1876), the Penal Code of Spain (1870), the Philippine Penal Code (1884), and the effect of the transfer of sovereignty and the fourteenth paragraph of section 5 of the Philippine Bill on the relation between Church and Sta...(Subscriber-Only)
Issues:
- Did the evidence establish that the accused committed the offense defined in Article 223 of the Penal Code (i.e., an act intended to force another to perform or to prevent performance of an act of worship)?
- If Article 223 was not established, did the accused's conduct constitute an offense under paragraph 1 of Article 571 (disturbing or interrupting a religious ceremony), and...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)