G.R. No. L-18238 - Castillo vs. Castillo

The case involves the United States, as complainant and appellee, versus Casiano Sadian, defendant and appellant, along with his co-accused (Monico Dada, Roman Dacpo, Basilio Sanchez, and Damian Tabonan).
The allegations arose from an information filed by the provincial fiscal of Ilocos Norte in the Court of First Instance, charging the accused with forming a secret political society named "Kanayouan."
The society’s purported purpose was to obtain Philippine independence by means of insurrection, treason, and rebellion against the US government, in violation of Act No. 292 of the Civil Commission.

On Sunday, July 5, 1903, while visiting a house in the barrio Pias, witnessed the arrival of Casiano Sadian, Sergio Sadang, and Sergio Sancali.
Casiano Sadian invited him to join and, to prove his affiliation, made an incision on his forearm and wrote the witness’s name in his own blood; the witness then signed his name with a cross.
He was later taken to the Cabuit forest on July 6, where a similar incision was made on his arm by accomplices, including Gavino Umayam working under Valentin Butardo.
The witness recounted that he was told privately by Gavino to report these events to the Constabulary and confirmed that similar acts of incisions were performed on others.

Testified that the accused voluntarily joined the society or party organized by him and his brother Canuto.
Identified documents related to this organization (with translations in the record and originals preserved in other cases).
Asserted that his invitation to join was in preparation for the upcoming presidential elections, and that the incision (a symbolic act to bind loyalty) was performed to secure commitment.

Initially stated that Valentin Butardo made the incision on Ariston Umayam at the time of his oath-taking as a member.
Later, he clarified that it was Casiano Sadian who performed the incision in Umayam’s arm in his presence.

Sergio Sancali testified he only knew by hearsay that the accused were members of the society, without personal knowledge of the initiation ritual.
Roman Taboan, Roman Dacpo, Monico Dado, and Basilio Sanchez testified that at Valentin Butardo’s instance, they joined the society, taking an oath to defend the country, though they did not witness the ceremony of incision on Ariston Umayam.

The crime charged is defined and penalized under section 9 of Act No. 292, which targets the organization of secret societies with objectives of insurrection against the government.
The acts committed (the incisions, oath-taking, and recruitment) clearly fall within the ambit of the said section, not constituting the crime of conspiracy under section 4 of the Act.
Casiano Sadian, who held the office of teniente in Gaang, denied the allegations and claimed that the incision on the witness was merely a sign of fraternity and political solidarity during an election period.

Casiano Sadian pleaded not guilty, denying the accuser's characterization of the events.
He argued that his actions were performed as a gesture of camaraderie rather than as an act of inciting rebellion.
Despite his defense, the weight of the evidence – including the multiple witness testimonies – pointed to his active involvement in organizing the society for the purpose of fomenting insurrection.

Whether the cumulative testimonial evidence is sufficient to prove beyond reasonable doubt that Casiano Sadian participated in forming the secret political society "Kanayouan."
Whether the act of making incisions and administering oaths constitutes proof of active recruitment and involvement in a subversive organization.

Whether the actions of the accused fall under the crime defined by section 9 of Act No. 292, specifically in terms of organizing a society with the intent of rebellion.
How to differentiate the acts constituting insurrection from those that might be merely seen as political association or conspiracy.

Whether Casiano Sadian’s position as teniente contributed to his culpability by exploiting his office to recruit proselytes among his neighbors.
Whether his actions were motivated by criminal intent, as required under the statute, rather than being benign expressions of political support.