Case Digest (G.R. No. 1481)
Facts:
- Defendants: Liberato Exaltacion and Buenaventura Tanchinco.
- Charge: Rebellion against the United States Government in the Philippines.
- Date of Information Filing: March 26, 1903.
- Allegation: Defendants swore allegiance to the Katipunan Society, aimed at overthrowing the government by force, after November 4, 1901.
- Key Testimony: Don Pablo Tecson, provincial governor of Bulacan, testified about the arrest in March 1903.
- Evidence: Documents signed by the defendants, captured in the encampment of bandit leader Contreras, presented as evidence.
- Defendants' Claim: They were forced to sign the documents under threat of death by brigands.
- Corroborating Witnesses: Exequiel Casa, Fernando Nieto, and the municipal president of Meycauayan.
- Document Dates: July 4 and July 17, 1902, containing oaths of allegiance to the Katipunan Society.
- Additional Testimonies: Lazaro Yusay and Bonifacio Morales confirmed the defendants' capture and reporting to local authorities.
- Lower Court: Imposed a penalty based on the evidence presented.
Issue:
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Ruling:
- Criminal Liability: The Supreme Court ruled that the defendants were not criminally liable for rebellion due to acting under duress.
- Sufficiency of Evidence: The Supreme Court found the evidence insufficient to establish the defendants' guilt b...(Unlock)
Ratio:
- Duress: The Supreme Court, through Justice Torres, held that the defendants were relieved from criminal liability due to the duress under which they acted.
- Kidnapping and Compulsion: Evidence showed the defendants were kidnapped by brigands from the Contreras band and compelled to sign the documents while in captivity.
- Reporting to Authorities: Defendants' immediate reporting to local authorities upon release corroborated their testimony and demonstrated their innocence.
- Insufficient Evidence: Prosecution's evidence, particularly the documents signed by the defendants, was insufficient to prove guilt beyond a reasonable doubt.
- Credibility of Testimonies: Minor discrepanc...continue reading
Case Digest (G.R. No. 1481)
Facts:
In the case of "People vs Exaltacion," the defendants, Liberato Exaltacion and Buenaventura Tanchinco, were charged with the crime of rebellion against the United States Government in the Philippines. The provincial fiscal of Bulacan filed the information on March 26, 1903, alleging that the defendants had willfully and illegally sworn allegiance to the Katipunan Society, an organization aimed at overthrowing the government by force, subsequent to November 4, 1901. During the trial, Don Pablo Tecson, the provincial governor of Bulacan, testified that Exaltacion and Tanchinco were arrested in March 1903. The police had previously captured documents in the encampment of a bandit leader named Contreras, located in Langca, Meycauayan, Bulacan. These documents, signed by the defendants, were presented as evidence. Both defendants claimed they were forced to sign these documents under threat of death by brigands. Witnesses, including Exequiel Casa, Fernando Nieto, and the municipal president of Meycauayan, corroborated the defendants' claims. The documents dated July 4 and July 17, 1902, contained oaths of allegiance to the Katipunan Society. The defendants testified that they were captured and coerced into signing these documents. Additional witnesses, inc...