Case Summary (G.R. No. 976)
Applicable Law
- Philippine Organic Act of 1902 (fundamental law governing the Islands at the time)
- Act No. 292 of the United States Philippine Commission, Section 14 (offense of violating oaths of allegiance)
- Presidential Proclamation of Amnesty (granting pardon for “offenses of treason and sedition”)
Definition of the Oath-Violation Offense
Section 14 of Act No. 292 punishes any person who, having taken an oath to recognize U.S. authority in the Philippine Islands, subsequently violates its terms—namely, allegiance to the United States, obedience to its laws and orders. Penalties include a fine up to $2,000, imprisonment up to ten years, or both.
Scope and Purpose of the Amnesty Proclamation
The respondent, a former insurgent officer, sought to invoke a presidential amnesty that covered “offenses of treason and sedition.” To qualify, the offense must either have been committed under insurrectionary orders or fall within the proclamation’s broad language forgiving political crimes against the state.
Technical Distinctions: Treason, Sedition, and Oath Violation
- Treason (Act No. 292, §1): Levying war against the United States or Philippine Government, or adhering to enemies.
- Sedition (Act No. 292, §§5–6): Public, tumultuous rising to achieve political aims by force or outside legal methods.
- Oath Violation (Act No. 292, §14): Breach of the specific promise of allegiance, which may occur without an act of treason or sedition. Conversely, treason or sedition can be committed by one who never took such an oath.
Analysis of the Respondent’s Conduct
The lower court found that Abad, after surrendering in April 1901, lied to a U.S. officer about concealed rifles—denying both their existence and location. While this denial arguably breached his oath, it simultaneously could constitute treason (aiding enemies by withholding arms).
Broader Construction to Effectuate Amnesty
Rather than narrowly parse “treason” and “sedition” in their strict legal senses, the Court adopts a liberal interpretation of the proclamation’s terms. All political offenses defined in Act No. 292—treason, insurrection, conspiracy, sedition, libel, secret
...continue readingCase Syllabus (G.R. No. 976)
Case Background and Procedural History
- The defendant, Maximo Abad, was charged and convicted under section 14 of Act No. 292 of the United States Philippine Commission for violation of an oath of allegiance.
- Section 14 penalizes any person who, having sworn to recognize U.S. authority in the Philippine Islands, later violates the terms of that oath.
- Abad, a former insurgent officer, claimed entitlement to the benefit of an amnesty proclamation issued by the President of the United States.
- The record contained no evidence that Abad’s offense was committed pursuant to orders from insurrectionary authorities, spawned from internal Spanish–Filipino feuds, or resulted from Filipino factional dissensions.
Statutory Provision and Definitions
- Section 14, Act No. 292: Any person who has taken an oath to recognize U.S. sovereignty and later violates its terms is subject to a fine up to $2,000, imprisonment up to ten years, or both.
- Section 1, Act No. 292 (Treason): Levying war against the United States or Philippine government, or adhering to enemies and giving them aid and comfort.
- Section 5, Act No. 292 (Sedition): Public, tumultuous rising to achieve political objectives by force or outside legal methods.
- Sections 3, 4, and 7 define insurrection, misprision, and conspiracy related to treason or insurrection.
Nature of the Offense Under Section 14
- Violation of an oat