Case Summary (G.R. No. 206404)
Definition of Sedition under Act No. 292
Section 5 of Act No. 292 criminalizes any public, tumultuous rising to compel government or officials, by force or illegal means, to refrain from performing duties or to alter administrative orders. However, this provision must be read in harmony with the Philippine Bill’s express protections of free speech, peaceful assembly, and petitioning for redress.
Prosecution’s Allegations versus Record Evidence
The government argued that the assembly was neither peaceful nor limited to petitioning but coerced the council’s free exercise of duties. On review, witness testimony revealed the crowd’s unarmed status, their voluntary display of empty hands and garments to American officials, and an orderly demeanor inconsistent with a tumultuous uprising.
Assessment of Disorderly Conduct and Imperative Tone
While some demonstrators spoke in an “imperative” tone, evidence conflicted as to its pervasiveness. The mere firmness of voice in presenting grievances does not transform a lawful assembly into sedition. The petitioners sought and received permission to withdraw, and interactions with council members and American officials showed cooperative communication rather than violence.
Consideration of Threats and Collective Intent
Although certain individuals may have uttered threats, these were not publicly endorsed by the mass nor accompanied by any show of force. The municipal presidente’s claim of fear did not establish a real threat of violence. Isolated menacing remarks could render the speakers individually liable but did not convert the entire body into a seditious mob.
Protections for Peaceful Assembly and Limits on Sedition Prosecution
The right to assemble and petition, even when emotionally charged, must not be undermined by overstating instances of minor disorder. Prosecutors must distinguish between iso
...continue readingCase Syllabus (G.R. No. 206404)
Procedural History
- Appellants were indicted, tried, and convicted of the crime of sedition under Section 5 of Act No. 292 of the Philippine Commission.
- Each appellant was sentenced to six months’ imprisonment, a fine of 200 dollars, subsidiary imprisonment in case of insolvency, and payment of trial costs.
- The appellants appealed the conviction to the Supreme Court.
- The Supreme Court granted review and ultimately reversed the conviction.
Facts
- Prior to a regular morning session of the municipal council of San Carlos, Occidental Negros, approximately 500 residents assembled near the municipal building.
- Upon the opening of the council session, many of these residents entered the council chamber and demanded:
- The dismissal of the municipal treasurer.
- The dismissal of the municipal secretary.
- The dismissal of the chief of police.
- The crowd suggested the names of replacements and the council acceded, drafting a formal resolution outlining its reasons.
- That resolution was signed by all present councilors and several crowd leaders.
- The participants were wholly unarmed, save for a few carrying ordinary walking canes.
- Two American officials inquired into the gathering and were assured it was purely a petition for removal of officials.
- To demonstrate peaceful intent, members of the assembly displayed their jackets and camisas to show no concealed weapons.
- The assembly was generally orderly, with no evidence of physical violence or weapons intended for assault.
- The movement stemmed from religious factionalism in the town, the petitioners believing certain officials showed allegian