Case Summary (G.R. No. 12644)
Procedural Background
The legal proceedings commenced with a complaint filed by the provincial fiscal on December 7, 1915, under Article 223 of the Penal Code, addressing the defendants’ interruptions to the Catholic procession. The trial court ruled on August 25, 1916, sentencing Rigor, Goruspe, and de los Reyes to ten days of arresto and a fine, while dismissing charges against others. The defendants appealed the decision, maintaining their innocence.
Facts of the Case
The appellate court examined testimonies revealing that shortly after 8 p.m. on July 15, 1915, the procession began but was confronted by Rigor, Goruspe, and Reyes, who used clubs and sticks to obstruct it. Witnesses corroborated that they attacked Cayetano, causing the procession to disband in fear. The Aglipayan priest Rigor reportedly warned the participants not to pray publicly during this time, claiming prior advisories against the procession.
Medical Evidence
Medical examination of Cayetano demonstrated that he suffered light wounds during the confrontation. Testimonies indicated Rigor's presence at the scene and contradicted his claims of merely praying inside the church at the time of the disturbance.
Legal Provisions
Article 223 of the Penal Code criminalizes the use of threats or violence to compel or prevent religious worship. The prosecution argued the defendants’ actions violated this provision, as they forcibly disbanded the Catholic procession, which had the right to proceed unhindered.
Evaluation of Defendant’s Actions
The court emphasized that no authorities had forbade the procession and that the defendants lacked the legal authority to impede religious activities. Their violent confrontation aimed to dissolve the procession and prevent the celebration of Catholic rites constituted clear transgressions of Article 223.
Appellate Court's Decision
The appellate court reversed the lower court's classification of the incidents as a mere misdemeanor. It concluded that the defendants had engaged in deliberate violence to obstruct the religious assembly, warranting stricter penalties. The court determined there were no mitigating factors and imposed a sentence of three years, six months, and twenty-one days of prision correccional and a fine of 1,000 pesetas for each defendant.
Con
...continue readingCase Syllabus (G.R. No. 12644)
Case Background
- This case arises from a complaint filed by the provincial fiscal on December 7, 1915, against fourteen defendants, including Pedro Rigor, Mariano Goruspe, and Cipriano de los Reyes.
- The complaint charged them with a crime defined under Article 223 of the Penal Code, which addresses acts that prevent individuals from performing religious worship.
- On August 25, 1916, the trial court sentenced Rigor, Goruspe, and Reyes to ten days of arresto and a fine of 125 pesetas, with provisions for subsidiary imprisonment in case of insolvency.
- The case against Raymundo Capiral, Dalmacio Capiral, and Hermenegildo Tejada was dismissed, while other defendants were absolved with costs borne by the state.
Incident Description
- On the evening of July 15, 1915, about thirty residents of the barrio of Moriones in Tarlac began a religious procession from the Catholic church, carrying the image of the Virgin of the Immaculate Conception.
- Upon reaching the Aglipayan church, they were confronted by Rigor and others, who, armed with clubs and sticks, blocked the procession and directed them onto a dirty alternate route.
- Rigor warned the procession members against saying prayers during the novenary, leading to a confrontation with Maximo Cayetano, who was leading the procession.
- Violence ensued, with members of the procession being physically attacked, resulting in the image of the Virgin being abandoned and damaged.
Testimonies and Evidence
- Eyewitness testimonies from Cayetano and others confirmed that Rigor and his associates prevented the Catholic processi