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Criminal Law II Art 115 January 22, 2016 Ruth F. Melicor


CASE NAME: US vs. Bautista
PONENTE: Carson, J. Case Date: 1906-11-03
Case Summary:
Certain Filipinos in Hong Kong planned to voerthrow the US government in the Philippines.
One of its prime leaders traveled to Manila to organize an armed uprising and raise funds for
the same. The plans of treason failed. The current case involves the appeal of 3 people
convicted of being involved in such a conspiracy. The first in Francisco Bautista. The court
found him to be in conspiracy with the perpetrators since he forwarded 200 pesos to the
leader in Hong Kong and was present at the meetings where he declared that the
preperations were already “in readiness.” The second man accused, Tomas Puzon was also
convicted. He accepted a commission giving him leadership over certain forces and
executed obligations that came with such an acceptance. Although he claimed that he
did so only to avoid vexing his friend who recruited him into the plans of treason, the court
found that his actions belied his statements and that he voluntarily accepted such a
commission. Furthermore, although jurisprudence has stated that the acceptance of a
commission is not necessarily evidence against him, the court reasoned that unlike such
cases there was proof of voluntary acceptance and that the charge in this case was that of
a conspiracy. Thus, such acceptance gave evidence to his criminal relations to the
perpetrators. Lastly, the third man accused Ancieto de Guzman, was acquitted, reversing
the lower courts decision. deGuzman was found to have accepted bonds which were used
to raise funds for the conspiracy. However, the court found that this did not show that he
knew of the conspirators intentions, and furthermore he was found to have burned such
bonds the moment he knew what it really was.
Rule of Law:
Provision/s most relevant to this case.

Detailed Facts:
In 1903, a junta was organized and certain Filipinos residing in Hong Kong entered into a
conspiracy to overthrow the US gov’t in the Philippines by force and establishing in its place
the “Republica Universal Democratia Filipina. Prim Ruiz was recognized to be the titular head
and Artemio Ricarte as chief of the military forces. The latter traveled to Manila where he
held a number of meetings to take in new members into the conspiracy. To further the
elistments and raising of funds for the campaign numerous commissions and bonds were
granted to conspirators. However, the conspirators failed in their efforts.

The accused in this case are Francisco Bautista, Ancieto de Guzman, and Tomas Puzon. They
were convicted by the Court of First Instance of Manila of “conspiracy to overthrow, put
down, and destroy by force the Gov’t of the US in the Philippine Islands” which is against
Section 4 of Act 292 of the Philippine Commission.

Bautista
Bautista was found to be an intimate friend of Ricarte. Bautista forwarded Ricarte 200 pesos
he also was present in several of the meetings organized. In one of those meetings Bautista
assured Ricarte that all the preparations necessary were already made and that “he had

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held the people in readiness.”

Puzon
Puzon was proven to have been a leader in the movement, also in confidence of Ricarte.
He was authorized to distribute bonds and appoint officials. He was united with the
conspirators, through his association with Jose Munoz. It was the latter that offered him the
position of brigadier-general of the signal corps, and evidence found that he had fulfilled the
relevant duties that showed accordance with such a commission. However, Puzon claimed
that he had never united with the conspirators, claiming that he only “accepted” the
position because he did not want to hurt Puzon’s feelings. However, this was in contradiction
to the signed written statement he made when he was arrested. The trial found that he freely
and voluntarily made the decision to accept the commission.

De Guzman
de Guzman was convicted because he was found to have accepted bonds from the
conspirators, for the purpose of raising funds.
Issue:

S(1)WoN the constitutional provision requiring the testimony of at least two witnesses to the
same overt act should be applied in this case.

S(2). WoN Bautista and Puzon should be convicted.

S(3) WoN de Guzman should be convicted.

Holding:
S(1) No. The crime of conspiracy to commit treason is a separate offense from treason, thus
the stated provision is not applicable in this particular case.

S(2) Yes. They both should be convicted. With regards to Bautista, the court ruled that there
clearly was a conspiracy to commit the crime. In the case of Puzon, the court reasoned that
although previous cases have ruled that acceptance or possession of an appointment as an
officer of the military forces of the conspiracy is not considered as evidence against the
accused, there is a clear distinction in this particular case, since Puzon accepted and
assumed the obligations from that acceptance. Since the charge is conspiracy, then this
could be taken as evidence of “his criminal relations with the conspirators.”

S(3)
No. The lower court’s decision convicting de Guzman should be reversed. The accused
merely accepted bonds, but such does not show that he knew about the conspiracy when
he received it. Furthermore, additional evidence found that as soon as he discovered the
contents of the bundle he received, he burned it. He was found to never have relation to
the dealings of the conspirators.

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Ruling:
The decision was affirmed with regards to Bautista and Puzon, modified by removing the
subsidiary imprisonment in the event of insolvency to pay respective fines. The Court of First
Instance’s ruling with regards to de Guzman is reversed, thus he is acquitted from the
charges made against him.

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