Case Digest (G.R. No. 2189)
Facts:
The United States v. Francisco Bautista et al., G.R. No. 2189, November 03, 1906, the Supreme Court En Banc, Carson, J., writing for the Court.The plaintiff was the United States (appellee); the defendants and appellants were Francisco Bautista, Aniceto de Guzman, and Tomas Puzon. The defendants were convicted in the Court of First Instance of Manila for conspiracy "to overthrow, put down, and destroy by force" the Government of the United States in the Philippine Islands and the Government of the Philippine Islands, as defined in §4 of Act No. 292 of the Philippine Commission. Sentences: Bautista — four years' imprisonment with hard labor and a ₱3,000 fine; De Guzman and Puzon — each three years' imprisonment with hard labor and ₱2,000 fines; all were also ordered to pay costs and to suffer subsidiary imprisonment in case of insolvency.
The record showed that late in 1903 a junta in Hongkong, headed titularly by Prim Ruiz and militarily by Artemio Ricarte, organized a conspiracy to establish the "Republica Universal Democratica Filipinos." Ricarte clandestinely returned to Manila (steamship Yuensang) and held meetings in Manila and neighboring provinces to recruit members, issue bonds to raise funds, grant commissions to officers, and prepare armed resistance. The conspirators actually took the field and engaged authorities, though they ultimately failed to overthrow the government.
The evidence as to the appellants varied. Bautista, a Manila resident and intimate friend of Ricarte, sent Ricarte ₱200 secretly, attended several meetings, and told Ricarte he "held the people in readiness." Puzon was recruited by R. Munoz, accepted a commission as brigadier-general of the signal corps, and at trial denied participation but had signed a written statement at arrest admitting his employment in the organization; that confession was proven voluntary. De Guzman's conviction rested largely on his acceptance of several bonds prepared by the conspirators; he claimed ignorance of their nature, destroyed them upon discovering their contents, and denied further involvement.
On appeal to the Supreme Court (G.R. No. 2189), the Court reviewed the trial record and prior authorities bearing on the probative force of possessing commissions or bonds. The Court affirmed the convictions of Bautista and Puzon (but struck the subsi...(Subscriber-Only)
Issues:
- Does the constitutional requirement of two witnesses to the same overt act or confession in open court, applicable to treason, apply to a prosecution for conspiring to commit treason?
- Did the evidence suffice to convict the appellants — Francisco Bautista, Tomas Puzon, and Aniceto de Guzman — of the conspiracy defined in §4 of Act No. 292?
- Was the trial court authorized to impose subsidiary imprisonment for failure to pay the...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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