G.R. No. 12644 - People vs. Rigor

On the evening of July 15, 1915, shortly after 8 o’clock, about thirty residents of the barrio of Moriones in the municipality of Tarlac, accompanied by numerous women and children, embarked on a religious procession.
The procession, composed of Catholics from the local church, was observing the novenary by reciting prayers and carrying the image of the Virgin of the Immaculate Conception.

As the procession advanced along the town’s streets, it arrived in front of the Aglipayan church situated on Calle San Agustin.
Several men, including key figures—Pedro Rigor (an Aglipayan priest), Mariano Goruspe, and Cipriano de los Reyes—were posted at this location.
Armed with clubs and sticks, these men and their companions obstructed the Catholic procession, forcing its members to divert onto an alternative, unsanitary route.
Prior to the incident, Rigor had reportedly warned the procession not to hold novena prayers in the streets.

Maximo Cayetano, the conductor of the procession and leader of the novenary prayers, responded by asserting that he was entitled to perform a good deed.
Following his reply, Rigor, Goruspe, Reyes, and other companions initiated an assault on Cayetano using sticks, clubs, and physical force.
The violent encounter caused panic among the procession members, leading to its disbandment.
During the disturbance, the sacred image of the Virgin was knocked down, its crown went missing, and one of its hands was broken.

Eyewitness testimonies were presented by Maximo Cayetano and other witnesses (Hilario de los Santos, Roman Yamson, and Bartolome Licu), who confirmed that the defendants, along with unidentified companions, blocked the procession and maltreated its participants.
A medical certificate from Dr. Juan Nepomuceno attested to slight wounds sustained by Cayetano as a result of the assault.
The defense witness, Teodoro Lacsamana, a policeman, corroborated the occurrence of the tumult and the presence of the accused at the scene.

The three defendants—Pedro Rigor, Mariano Goruspe, and Cipriano de los Reyes—entered a plea of not guilty and denied the charge.
Rigor, in particular, stated he was praying in the Aglipayan church at the time and claimed he only sent an emissary to investigate the disturbance once he heard commotion.
These statements were challenged by the witnesses for the prosecution who refuted the defendants’ version of events.
The case was initially filed by the provincial fiscal on December 7, 1915, leading to an earlier judgment on August 25, 1916, that included lighter penalties for some defendants and dismissal or absolution for others.

The crime charged was based on Article 223 of the Penal Code, which prescribes penalties for using threats, violence, or equivalent compulsion to either force someone to perform an act of worship or to prevent them from doing so.
This provision was noted as the sole applicable statute in cases involving interference with religious acts and worship, distinguishing the present case from other provisions like Article 571.

The facts were contrasted with a prior case (United States vs. Balcorta), where interruption of a religious service was deemed a misdemeanor, noting significant factual differences.
The current case involved deliberate violent actions intended to completely disperse the procession and prevent the citizens from performing their religious exercise.

Whether the actions of the defendants—by means of violence and the use of clubs and sticks—constituted an unlawful interference that prevented the performance of a legitimate religious procession.
Whether the conduct of the defendants, given that it resulted in the dispersal of the procession and the desecration of a sacred image, falls under the penalties prescribed by Article 223 of the Penal Code or should rather be classified as a misdemeanor under Article 571.
The determination of whether the mere interruption versus the forceful and violent prevention of a religious act should attract a harsher penalty under the law.
How the defense’s version of events, including claims of unauthorized involvement and minimal disturbance, stands against the overwhelming eyewitness and medical evidence.
Whether the decision in the present case aligns with constitutional principles protecting the free exercise of religious worship as enshrined in the Treaty of Paris and the Philippine Bill of Rights.