Title
The United States vs. Mateo Lapus et al.
Case
G.R. No. 1222
Decision Date
Jan 21, 1905
A 1902 armed raid on Cabiao by "Santa Iglesia" members, targeting authorities and wealthy landowners, led to sedition convictions for violence and intimidation.

Case Digest (G.R. No. 174208)
Expanded Legal Reasoning Model

Facts:

  • Procedural Background
    • The provincial fiscal of Nueva Ecija filed a complaint in the Court of First Instance against Mateo Lapus, Bonifacio Bautista, Eufino Ordonez, Victorino Manalang, and Pedro Bautista among others.
    • The complaint charged the accused with the crime of sedition based on their participation in a violent, politically motivated uprising.
  • Alleged Criminal Acts
    • On the night of June 3, 1902, a band of approximately four hundred men, including the accused, raided the town of Cabiao.
    • The assailants were heavily armed with guns, revolvers, talibones, bolos, and clubs.
    • The band advanced through the streets firing shots, yelling, and intentionally frightening the inhabitants.
  • Specific Incidents During the Raid
    • Some members of the band entered the municipal president’s house while others invaded several private homes.
    • Approximately sixty to seventy residents, including both prominent and ordinary townspeople, were taken captive.
    • Captives were transported to locations such as Patatan and Libutad on the Chico River, where they were detained until about noon the following day before being released.
    • The raiders threatened severe retribution, warning that should they comply with orders from Felipe Salvador—chief of the association known as “Santa Iglesia”—all captives would be killed.
  • Testimonies and Evidence
    • Multiple witnesses and residents provided evidence regarding the raid and the oppressive actions of the band.
      • Gregorio Reyes testified that he had been beaten with a club by one of the accused, Rufino Ordonez, when he pleaded for the release of his master, Genaro Albina.
      • The municipal president, Jose Crespo, and the justice of the peace, Francisco Crespo, corroborated witness statements, recounting details of the assault such as the seizure of personal items (rain coat, cap, belt, clothes) and the destruction of property (door lock, boots).
    • Constabulary inspectors, including Cayetano Canda and Richard Kavanaugh, further testified on the organized nature of the raid and the association’s political agenda.
      • Evidence highlighted that the band, known alternately as “Santa Iglesia” and “Gabinistas,” aimed at persecuting public officials, military personnel, and wealthy landowners as retaliation for perceived injustices.
      • The statements emphasized that the association’s organized structure was intended for acts of hatred and vengeance with clear political and social motivations.
  • Statutory Basis of the Charges
    • The acts committed by the band were characterized as sedition under paragraphs 3 and 4 of section 5 and punished by section 6 of Act No. 292 of the Civil Commission.
    • The evidence indicated that even though the band’s ultimate objective was not fully realized, their conduct already consummated the crime of sedition.

Issues:

  • Whether the acts committed by the accused constituted the crime of sedition as defined under Act No. 292.
    • The issue centered on the interpretation of the elements of sedition and whether the actions met the statutory requirements.
  • The determination of the accused’s liability as principals in the crime of sedition.
    • Consideration was given to the active participation and membership of the accused in the band and illegal association known as “Santa Iglesia.”
  • The effectiveness of the evidence presented by the prosecution in rebutting the exculpatory pleas of the defendants.
    • The accused had pleaded not guilty, but the court had to assess if the evidence was sufficient to overcome such defenses.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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