Title
People vs. Rigor
Case
G.R. No. 12644
Decision Date
Dec 22, 1917
A Catholic procession in Tarlac was violently disrupted by Aglipayans, leading to a Supreme Court ruling that upheld religious freedom under Article 223 of the Penal Code.

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 reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.