G.R. No. L-11870 - People vs. Cruz

Case Summary (G.R. No. L-11870)

Petitioner and Respondent

Petitioner: The People of the Philippines (Plaintiff-Appellee)
Respondents/Appellants: Fermin Tolentino, Benito Cruz and Paterno Cruz (Defendants-Appellants)

Key Dates

May 28, 1946 onward: Organized uprising by HMB against the Government.
March 20–21, 1951: Raid on Hardie farm in Antipolo and combat in Pililla, Rizal.
April 21, 1951: Armed engagement in Moron, Bataan.
November 15, 1952: Skirmish in San Mateo, Rizal.
November 23, 1953: Filing of information in the Court of First Instance of Rizal.
October 16, 1961: Decision by the Supreme Court of the Philippines.

Applicable Law

Under the 1935 Philippine Constitution and the Revised Penal Code, the appellants were indicted for the complex crime of rebellion, with robbery, homicide and arson as means and in furtherance thereof. Article 135, Revised Penal Code, governs penalties for rebellion with rank or command responsibilities.

Facts of the Rebellion and Related Offenses

The information alleged that beginning May 28, 1946, and continuously thereafter, the accused conspired as officials or members of the Communist Party’s HMB to overthrow the Government by armed uprising. In connection with the rebellion, they committed:

March 20, 1951 raid on John D. Hardie’s residence in Antipolo, Rizal—robbery of personal property valued at P5,000, binding and execution of Hardie, his foreman Donald Capuano, and Mrs. Irene Hardie.
March 21, 1951 armed conflict between HMB’s FC 32 and Philippine Army units in Pililla, Rizal.
April 21, 1951 attacks led by Tolentino’s FC 25 against Armed Forces detachments in Moron and Hermosa, Bataan—resulting in deaths and injuries.
November 15, 1952 skirmish by FC 46 members in San Mateo, Rizal, against military and civilian commando units.
Multiple encounters in Tanay, Rizal, and ambushes such as the 1949 assassination of Mrs. Aurora A. Quezon in Nueva Ecija.
Raids on Camp Makabulos, Tarlac (August 25, 1950), and forced appropriation of Provincial Treasury funds in Laguna (August 26, 1950).
Similar acts of murder, arson, kidnapping and plunder throughout Rizal and other provinces.

Prosecution Evidence

Recovery of the radio and typewriter looted from the Hardie farm at a captured Huk camp.
Arrest of Benito and Paterno Cruz on July 26, 1951; their affidavits (Exhibits V, X, AA, Y) admitting Huk membership and Benito’s rank as “Commander Saling.”
Testimony of former HMB members (Nicolas Lipunan and Tomas Timbresa) identifying both brothers at the Hardie raid and implicating Benito as one of the shooters.
Multiple witnesses attesting to Tolentino’s command positions (FC-18, FC-25), participation in raids and killings (Orani, Culis, Morong, Makabulos), and discovery of his alias on victims’ tags.
Eight separate written confessions by Tolentino (Exhibits BB, OO, PP, HH, II, etc.) detailing his progression from private to commanding officer of FC-25, armaments, engagements, and organizational structure.

Defense Evidence

Appellants alleged their confessions were signed under duress and presented community character witnesses.
Tolentino denied holding any rank or alias “Commander Caviteno,” contested maltreatment claims, and disavowed authorship of tags found on victims.
No physical signs of maltreatment or credible motives for prosecution witnesses to fabricate testimony were shown.

Court’s Findings

The trial court and Supreme Court found the prosecution evidence conclusive. Confessions were consistent, detailed, free of indicia of coercion, and corroborated by independent witnesses. Defendants failed to identify alleged soldiers who mistreated them or substantiate their duress claims. Character evidence did not outweigh direct proof of active participation in rebellion-related offenses.

Clas

Case Syllabus (G.R. No. L-11870)

Facts of the Case

On November 23, 1953, the Provincial Fiscal of Rizal filed an information charging appellants with a “complex crime of rebellion, with multiple murder, robberies and arsons,” allegedly beginning May 28, 1946 and continuing thereafter.
The accused were alleged to be ranking officers or members of the Communist Party of the Philippines and its armed wing, the Hukbong Mapagpalaya ng Bayan (HMB or Hukbalahap).
The conspiracy involved public uprisings, armed raids, ambushes, attacks on government forces and civilians, murders, pillages, lootings, arsons and the organization of barrio groups for logistical support.
Specific incidents charged included:
- I. Raid on the Hardie Farm, Antipolo (March 20, 1951): forcible entry, robbery of P5,000 worth of goods, tying and shooting to death John D. Hardie, Donald Capuano and Irene W. Hardie.
- II. Armed clash at Pililla, Rizal (March 21, 1951) between Huk FC 32 and 14th BCT, AFP.
- III. Attacks by FC 25 under Fermin Tolentino at Moron and Hermosa, Bataan (April 21, 1951 and later).
- IV. Engagement at San Mateo, Rizal (November 15, 1952) involving FC 46, RECO 4.
- V & VI. Encounters in Tanay, Rizal with Huks under Silang and Aladdin (April 5 & December 11, 1951).
- VII. Ambush of Mrs. Aurora A. Quezon convoy, Bongabong, Nueva Ecija (April 28, 1949), resulting in multiple deaths.
- VIII. Raid on Camp Makabulos, Tarlac (August 25, 1950), arson and killing of military officers and nurse Rosario Sotto.
- IX. Treasury raid, Sta. Cruz, Laguna (August 26, 1950): forced opening of provincial vault, seizure of P80,000, office equipment, arson and looting.
- X. Numerous similar atrocities across Rizal and other provinces.

Arrest, Seizure, and Prosecution Evidence

In the evening of March 20, 1951, government forces attacked a Huk camp in the Sierra Madre, recovering the typewriter and radio taken from the Hardie Farm.
On July 26, 1951, Benito and Paterno Cruz were arrested in San Rafael, Montalban, Rizal; they executed affidavits admitting Huk membership and command roles (Exhibits V, X, AA, Y), later claiming duress.
Witnesses Nicolas Lipunan and Tomas Timbresa, former Huks, testifie