Facts:

In the case of The United States vs. Juan Panganiban, G.R. No. 5584, decided on October 29, 1910, the defendant, Juan Panganiban, was convicted by the Court of First Instance of Rizal for violating Act No. 1696. The conviction stemmed from Panganiban's actions of knowingly and willfully exposing a sign to public view, which was fastened to a post on a public street in Antipolo, Rizal, approximately seven meters from his residence. This exposure occurred from January 7, 1908, until March 16 of the same year. The sign in question was quadrangular, measuring a little over a meter long and almost half a meter wide. It featured a triangle containing a rising sun and three stars, bordered by red and blue stripes, with the inscription "UNION NACIONALISTA PARTY" prominently displayed. The sign commemorated a mass meeting held on January 27, 1907, where the townspeople expressed their views on the capability of Filipinos to govern themselves independently. The design o...

Facts:

1. Context of the Case:
The defendant, Juan Panganiban, was convicted by the Court of First Instance of the Province of Rizal for violating Act No. 1696. He was sentenced to pay a fine of P500 and the costs. He appealed the decision.

2. The Act in Question:
Act No. 1696 prohibits the display of flags, banners, emblems, or devices used during the late insurrection in the Philippines to identify those in armed rebellion against the United States.

3. The Defendant’s Actions:
Juan Panganiban knowingly and willfully exposed a tablet or sign to public view by fastening it to a post on the side of a public street in Antipolo, Rizal. The sign was displayed from January 7, 1908, until March 16, 1908, approximately 7 meters from his house.

4. Description of the Sign:

• The sign was quadrangular, over a meter long and almost half a meter wide.
• It featured a triangle with a rising sun and three stars, surrounded by red and blue stripes with a white space in between.
• The inscription read:
  "UNION NACIONALISTA PARTY. In commemoration of the mass meeting held, Sunday the 27th of January, 1907, at Antipolo by the people of the town for the purpose of expressing their views on the question of the capacity and ability of the Filipino people to maintain a free and independent government."

5. Comparison to the Insurgent Flag:
The insurgent flag used during the late insurrection was also quadrangular, with a triangle enclosing a rising sun and three stars. The background was divided into red and blue sections. The sign displayed by Panganiban was not an exact reproduction but closely resembled the most prominent features of the insurgent flag.

6. Intent and Effect:
The sign was designed to evoke the insurgent flag and stir up feelings of rebellion and hatred against the constituted authorities. Its display was intended to excite the people and challenge the government.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Violation of Act No. 1696:
   The court ruled that the sign, though not an exact reproduction of the insurgent flag, was sufficiently similar to evoke the same effect on the public. The display of such a sign was intended to incite rebellion and hatred against the government, which is precisely what Act No. 1696 seeks to prevent.

2. Intent to Cause Injury:
   The court emphasized that the defendant’s intent to cause injury to the government was manifest. The design and inscription on the sign were calculated to stir up anti-government sentiments, making it a clear violation of the law.

3. Precedent:
   The court cited United States v. Go Chico (14 Phil. Rep., 128), where the display of medallions featuring Emilio Aguinaldo and the insurgent flag was held to violate Act No. 1696. The court found that the present case was analogous, even though the sign was not an exact reproduction of the flag.

4. Legislative Intent:
   The court noted that the legislative intent behind Act No. 1696 was to prevent the display of symbols associated with rebellion. The law was enacted to address the specific conditions in the Philippines at the time, and its prohibition was broad enough to cover signs like the one displayed by Panganiban.