Rebellion/insurrection
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
BAYANI ESPIRITU, ET AL., accused,
BAYANI ESPIRITU and TEOPISTA VALERIO, defendants-appellants.
**Facts:**
The case involves several individuals, including Amado V. Hernandez, accused of rebellion in the
Philippines between 1945 and 1950. The defendants were associated with the Communist Party of the
Philippines (CPP) and the Hukbalahap (HMB), an armed peasant group. The court examined their
activities, such as delivering speeches in favor of Communism, soliciting contributions, and alleged
connections with the HMB.
The defendants include:
- **Amado V. Hernandez:** Accused of being a CPP member and giving seditious speeches.
- **Juan J. Cruz:** Associated with the CPP and CLO (Civil Liberties Union).
- **Amado Racanday:** Accused of being a Communist, CLO Secretary, and involved with the HMB.
- **Genaro de la Cruz:** Accused of being a Communist, CLO Treasurer, and receiving contributions.
- **Julian Lumanog:** Accused of organizing HMB units and participating in Communist activities.
- **Fermin Rodillas:** Accused of soliciting contributions and providing asylum to the Huks.
- **Bayani Espiritu:** Accused of being a Communist, serving as a courier, and communicating with the
party.
- **Teopista Valerio:** Accused of being a Communist, Huk courier, and having connections with top
Communists.
The court considered various factors, such as the nature of their involvement, membership in the CPP or
HMB, and specific actions related to rebellion.
The prosecution focused on proving the defendants' participation in rebellion or conspiracy to commit
rebellion during the specified period.
**Issues:**
1. Whether mere membership in the Communist Party or the Civil Liberties Union (CLO) implies liability
for rebellion or conspiracy to commit rebellion.
2. Whether the accused were involved in actual rebellion or conspiracy to commit rebellion, considering
their roles in the CPP, CLO, and HMB.
3. The guilt or innocence of each defendant based on their specific actions and associations.
**Ruling:**
1. The court holds that mere membership in the Communist Party or CLO does not automatically render
an individual liable for rebellion or conspiracy unless combined with actual advocacy or action.
2. The court distinguishes between the CPP, where membership alone might not imply guilt, and the
HMB, where membership implies participation in an uprising or rebellion.
3. Each defendant is individually assessed:
- **Amado V. Hernandez:** Found not guilty as there is no concrete evidence linking him to the
rebellion or conspiracy.
- **Juan J. Cruz:** Found not guilty due to lack of evidence connecting him with rebellion or
conspiracy.
- **Amado Racanday:** Absolved as there is insufficient evidence to prove his guilt beyond a
reasonable doubt.
- **Genaro de la Cruz:** Not found guilty of conspiracy due to lack of evidence related to his activities
around 1950.
- **Julian Lumanog:** Found guilty of conspiracy as he organized HMB units and contributed to the
rebellion.
- **Fermin Rodillas:** Found guilty as he showed sympathy by soliciting contributions for the HMB.
- **Bayani Espiritu:** Found guilty of conspiracy due to his constant communication with the
Communist Party and serving as a courier.
- **Teopista Valerio:** Found guilty of conspiracy as a member of both the Communist Party and
HMB.
The court dismisses charges against defendants not included in the decision and distinguishes the case
from People vs. Evangelista and Republic Act No. 1700, emphasizing that the charges are for actual
rebellion.
The final verdict includes absolution for some defendants and guilty verdicts for conspiracy to commit
rebellion with specific sentences for others.
crimes against national security and the law of
nations
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee
vs.
MAXIMO DELA PEÑA, Accused-Appellant
**Facts:**
Maximo De La Peña (appellant) appealed the decision of the Court of Appeals (CA), which affirmed with
modification the Regional Trial Court (RTC) decision finding him guilty of piracy under Presidential
Decree (PD) No. 532. The charges were related to an incident on September 24, 2005, along the river
bank of Barangay San Roque, Municipality of Villareal, Samar, where Maximo De La Peña, along with his
armed companions, allegedly committed piracy by forcibly taking and carrying away various items,
including sacks of copra, watches, gold, a cellphone, and cash, to the damage and prejudice of the boat
owner.
**Issue:**
The main issue was whether Maximo De La Peña was guilty of piracy. The appellant contended that the
prosecution failed to prove the elements of piracy under PD 532. He argued that the Information did not
properly allege the elements of the crime, particularly the location of the vessel in Philippine waters and
the seizure of its cargo, equipment, or personal belongings.
**Ruling:**
The court dismissed the appeal, affirming the CA's decision. The court held that the prosecution
adequately proved the elements of piracy under PD 532. It determined that the incident occurred in
Philippine waters along the river bank, and the appellant and his armed companions forcibly took and
carried away the vessel's cargo, equipment, and the personal belongings of the passengers. The court
found that the positive identification by the witnesses, particularly Julita, who knew the appellant for 16
years, was credible. The court also affirmed the penalty of reclusion perpetua without eligibility for
parole, as mandated by PD 532, despite the appellant's argument for a lower penalty. Additionally, the
court sustained the CA's modification in the award of damages, deleting actual damages and awarding
temperate damages instead, while also removing nominal, moral, and exemplary damages for lack of
legal and factual basis.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
ABUNDIO ROMAGOSA alias DAVID, defendant-appellant.
**Facts:**
Abundio Romagosa alias David appealed the decision of the lower court, which found him guilty of the
complex crime of rebellion with murders, robberies, and kidnappings. The charges were related to his
involvement as a ranking officer/member of the Communist Party of the Philippines (CPP) and Hukbong
Mapagpalaya Ng Bayan (HMBS or Hukbalahaps), conspiring to commit rebellion and engaging in various
criminal acts in furtherance of the rebellion, including the murder of Policarpio Tipay.
Romagosa entered a plea of guilty, and the prosecution recommended the penalty of life imprisonment.
The defense argued for a lower penalty, asserting that the crimes were absorbed by the rebellion and
should be considered simple rebellion.
**Issue:**
The main issue was whether Romagosa should be convicted of the complex crime of rebellion with
murders, robberies, and kidnappings or if the crimes should be considered simple rebellion.
**Ruling:**
The court modified the decision, holding that the lower court erred in convicting Romagosa of the
complex crime. Following the precedent set in People vs. Geronimo, the court ruled that crimes
committed in furtherance of rebellion, such as murders, robberies, and kidnappings, are absorbed by
and form part of the rebellion. As Romagosa entered a plea of guilty, he was deemed to have admitted
to the commission of the independent crime of murder. Consequently, he was convicted of the crimes
of simple rebellion and murder.
The court sentenced Romagosa to 8 years of prison mayor and a fine of P10,000 for rebellion, and an
indeterminate sentence of not less than 10 years and 1 day of prision mayor to not more than 18 years
of reclusion temporal for the murder. He was also ordered to indemnify the heirs of Policarpio Tipay in
the amount of P6,000, solidarily with Federico Geronimo (alias Commander Oscar), and others found
guilty in the killing.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
BENITO CRUZ, ET AL., defendants.
FERMIN TOLENTINO, BENITO CRUZ and PATERNO CRUZ, defendants-appellants.
**Facts:**
The case involves the appeal of Paterno Cruz, Benito Cruz, and Fermin Tolentino, who were convicted by
the Court of First Instance of Rizal for the crime of "rebellion with robbery with homicide" (Paterno Cruz
and Benito Cruz) and "rebellion with arson, with murder and robbery" (Fermin Tolentino). The charges
were related to their alleged involvement as ranking officers or members of the Communist Party of the
Philippines (CPP) and the Hukbong Mapagpalaya Ng Bayan (HMB or Hukbalahap) in various criminal acts
committed in furtherance of rebellion.
The specific incidents mentioned in the information include raids, ambushes, and attacks against
government forces and civilians, resulting in multiple deaths, injuries, lootings, arsons, and destruction
of properties. The appellants were accused of leading or participating in these actions as part of the
armed force of the CPP.
Paterno Cruz and Benito Cruz were implicated in the raid of the Hardie Farm, where they allegedly
participated in the killing of John D. Hardie, Donald Capuano, and Irene W. Hardie. Fermin Tolentino was
accused of commanding Huk attacks in various locations.
The appellants pleaded not guilty and contested the charges, claiming duress and coercion in their
confessions. However, the trial court found their denials insufficient to offset the overwhelming
evidence against them.
**Issue:**
The main issue was whether the appellants should be convicted of the crimes charged, considering their
alleged participation in various acts of rebellion, including robbery with homicide and arson.
**Ruling:**
The court affirmed the decision but modified the designation of the crime committed. The appellants
were found guilty of simple rebellion rather than the specific charges of "rebellion with robbery with
homicide" and "rebellion with arson, with murder and robbery." The penalties were adjusted
accordingly.
- Benito Cruz and Fermin Tolentino were sentenced to ten (10) years of prision mayor, with a fine of
P10,000 each.
- Paterno Cruz was sentenced to six (6) years, eight (8) months, and one (1) day of prision mayor, with a
fine.
The court upheld the lower court's decision, considering the acts as part of a simple rebellion, and found
the evidence against the appellants sufficient for their convictions.
FRANCISCO R. CARIÑO, petitioner,
vs.
PEOPLE OF THE PHILIPPINES and THE HON. COURT OF APPEALS, (1st
Division), respondents.
**Facts:**
Francisco Cariño was charged with the crime of rebellion, particularly as an accomplice, based on his
alleged association with the Communist Party of the Philippines and the Hukbong Mapagpalaya Ng
Bayan (Hukbalahaps). The charges included various acts of rebellion, such as ambushes, raids, and
attacks on government forces, between May 6, 1946, and September 12, 1950.
Cariño, a close friend of Dr. Jesus Lava, a prominent Communist leader, was accused of providing shelter
and sending supplies to Dr. Lava, who was wanted by the authorities. Additionally, Cariño, as a ranking
employee of the National City Bank of New York, was alleged to have assisted the Communist Party by
changing $6,000 into pesos and facilitating the opening of bank accounts for high-ranking Communists.
**Issue:**
The main issue was whether Francisco Cariño could be considered an accomplice in the crime of
rebellion based on his association with and support for the Communist Party and the Huks.
**Ruling:**
The court reversed the judgment, finding that Cariño's acts, such as providing shelter and sending
supplies, did not constitute direct cooperation in the execution of rebellion. The court emphasized that
there was no clear and conclusive evidence proving Cariño's membership in the Communist Party or the
Hukbalahaps. Furthermore, his actions were deemed insufficiently efficacious to make him guilty as an
accomplice in the crime of rebellion. As a result, Cariño was absolved from the charges.
IN THE MATTER OF THE APPLICATION FOR A WRIT OF HABEAS CORPUS, BERNABE
BUSCAYNO, JOSE MA. SISON and JULIET SISON, petitioners,
vs.
MILITARY COMMISSIONS NOS. 1, 2, 6 and 25, GENERAL FABIAN VER, GENERAL FIDEL
RAMOS, LIEUTENANT COLONEL VIRGILIO SALDAJENO, CAPTAIN MELCHOR A. ACOSTA
and REVIEW BOARD OF THE ARMED FORCES OF THE PHILIPPINES, respondents.
**Facts:**
The petitioners were accused of rebellion and subversion in connection with their alleged involvement
in activities against the government. The rebellion charge involved acts committed around February 4,
1972, and during the period from August 1973 to February 1974. The subversion charges were related
to specific acts committed by each petitioner in different years.
The petitioners raised the issue of double jeopardy, claiming that the rebellion and subversion charges
stemmed from the same set of facts and therefore constituted double jeopardy.
**Issue:**
The main issue revolved around whether the petitioners were subjected to double jeopardy by facing
both rebellion and subversion charges based on their alleged involvement in activities against the
government.
**Ruling:**
The court dismissed the petition and lifted the restraining order, ruling that there was no double
jeopardy. The court held that the rebellion and subversion charges were distinct offenses with different
overt acts, and thus, the petitioners were not placed in double jeopardy. The court emphasized that
rebellion and subversion are separate crimes, and the constitutionality of the Anti-Subversion Law had
been previously upheld. Therefore, the plea of double jeopardy by the petitioners was not sustained.
IN THE MATTER OF THE PETITION FOR HABEAS CORPUS. JUAN PONCE ENRILE, petitioner
vs.
JUDGE JAIME SALAZAR (Presiding Judge of the Regional Trial Court of Quezon City [Br.
103], SENIOR STATE PROSECUTOR AURELIO TRAMPE, PROSECUTOR FERDINAND R.
ABESAMIS, AND CITY ASSISTANT CITY PROSECUTOR EULOGIO MANANQUIL, NATIONAL
BUREAU OF INVESTIGATION DIRECTOR ALFREDO LIM, BRIG. GEN. EDGAR DULA TORRES
(Superintendent of the Northern Police District) AND/ OR ANY AND ALL PERSONS WHO MAY
HAVE ACTUAL CUSTODY OVER THE PERSON OF JUAN PONCE ENRILE, respondents.
G.R. No. 92164 June 5, 1990
SPS. REBECCO E. PANLILIO AND ERLINDA E. PANLILIO, petitioners,
vs.
PROSECUTORS FERNANDO DE LEON, AURELIO C. TRAMPE, FFRDINAND R. ABESAMIS,
AND EULOGIO C. MANANQUIL, and HON. JAIME W. SALAZAR, JR., in his capacity as
Presiding Judge, Regional Trial Court, Quezon City, Branch 103, respondents.
**Facts:**
On February 27, 1990, Senator Juan Ponce Enrile was arrested on charges of rebellion with murder and
multiple frustrated murder during a failed coup attempt. The arrest was based on an information filed
by a panel of prosecutors. Enrile filed a petition for habeas corpus, alleging constitutional rights
violations, including being charged with a non-existent offense and denied the right to bail.
**Issue:**
The primary issue revolves around the validity of the charges and the applicability of the doctrine
established in People vs. Hernandez. Specifically, whether the information properly charges an offense
and whether the Hernandez doctrine, which prohibits the complexing of rebellion with other offenses,
applies.
**Ruling:**
The Supreme Court ruled that the information does charge an offense – simple rebellion – as per the
doctrine in People vs. Hernandez. The Court upheld the Hernandez doctrine, prohibiting the complexing
of rebellion with any other offense committed on its occasion. The Court also emphasized that the
proper venue for asserting the right to bail was the trial court, and the petitioner should have followed
established judicial processes rather than coming directly to the Supreme Court. The case was
remanded to the trial court to fix the amount of bail for the petitioners.
**Additional Context:**
The decision also expressed concerns about the need to reevaluate laws on rebellion, suggesting that
there might be a need to either raise the penalty or clearly define and limit other offenses absorbed by
rebellion. The Court, however, acknowledged that such changes were within the purview of Congress,
not the judiciary.
Coup de état
LT. (SG) EUGENE GONZALES, LT. (SG) ANDY TORRATO, LT. (SG) ANTONIO TRILLANES IV,
CPT. GARY ALEJANO, LT. (SG) JAMES LAYUG, CPT. GERARDO GAMBALA, CPT. NICANOR
FAELDON, LT. (SG) MANUEL CABOCHAN, ENS. ARMAND PONTEJOS, LT. (JG) ARTURO
PASCUA, and 1LT. JONNEL SANGGALANG, Petitioners,
vs.
GEN. NARCISO ABAYA, in his capacity as Chief of Staff of the Armed Forces of the
Philippines, and B. GEN. MARIANO M. SARMIENTO, JR., in his capacity as the Judge
Advocate General of the Judge Advocate General’s Office (JAGO), Respondents.
**Facts:**
In 2003, members of the Armed Forces of the Philippines (AFP) engaged in an incident known as
the Oakwood Mutiny. The soldiers, led by Navy Lt. (SG) Antonio Trillanes IV, occupied the Oakwood
Premier Luxury Apartments in Makati City. They aired grievances against the government, leading to
a declaration of a state of rebellion by President Gloria Macapagal Arroyo. The soldiers eventually
surrendered, and legal proceedings ensued.
The National Bureau of Investigation (NBI) recommended filing coup d'etat charges against the
military personnel. The Department of Justice (DOJ) filed an Information, and the soldiers, including
petitioners, moved for the Regional Trial Court (RTC) to assume jurisdiction over the charges. The
military initiated its own investigation and recommended charges before a general court martial. The
RTC dropped the coup d'etat charges but was later asked by the DOJ to conduct a reinvestigation.
Petitioners argued that the military tribunal should not have jurisdiction over the charges. They
maintained that the RTC, in a previous order, declared that the offense of conduct unbecoming an
officer (Article 96 of the Articles of War) was not service-connected but absorbed in the coup d'etat
charge.
**Issue:**
Whether the military tribunal has jurisdiction over the charges of conduct unbecoming an officer and
a gentleman (Article 96 of the Articles of War) against the petitioners.
**Ruling:**
The Supreme Court ruled that the military tribunal has jurisdiction over the charges. Republic Act No.
7055 specifies service-connected offenses that fall under the jurisdiction of the court martial,
including violations of Articles 54 to 70, 72 to 92, and 95 to 97 of the Articles of War. The charge of
conduct unbecoming an officer (Article 96) is explicitly listed as a service-connected offense. The
Court held that the RTC's previous declaration that the offense was not service-connected was a
grave abuse of discretion and, therefore, void. The military courts retain jurisdiction over the case.
The petition for prohibition was dismissed.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
JOSE PATRIARCA, JR., alias "KA DJANGO," CARLOS NARRA, alias "KA JESSIE" and TEN
(10) JOHN DOES, accused-appellant.
**Facts:**
Jose Patriarca, Jr., also known by aliases "Ka Django," "Carlos Narra," and "Ka Jessie," appealed
the decision of the Regional Trial Court in Sorsogon, Branch 52, which convicted him of murder and
sentenced him to reclusion perpetua. He was accused, along with others, of murdering Alfredo
Arevalo on June 30, 1987, in Donsol, Sorsogon, Philippines.
The prosecution presented witnesses, including Nonito Malto, who testified that Patriarca and his
armed companions took Alfredo Arevalo from his residence, later shooting and killing him. Elisa
Arevalo, the victim's mother, identified Patriarca as the leader of the New People's Army (NPA)
responsible for the abduction and killing of her son.
Patriarca was also charged with the murders of Rudy de Borja and Elmer Cadag under different
cases.
During the trial, Patriarca applied for amnesty under Proclamation No. 724, which was granted by
the National Amnesty Commission.
**Issue:**
Whether the trial court erred in finding accused-appellant Jose Patriarca, Jr. guilty of the crime of
murder, an offense committed in pursuance or in furtherance of rebellion.
**Ruling:**
The trial court's decision was reversed and set aside. Jose Patriarca, Jr. was acquitted of the crime
of murder based on the grant of amnesty under Proclamation No. 724. The court ordered the
dismissal of related cases (Criminal Case Nos. 2663 and 2664) and the release of Patriarca, unless
he is being detained for some other legal cause. The Director of Prisons was instructed to report
compliance with the decision.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
ABUNDIO ROMAGOSA alias DAVID, defendant-appellant.
**Facts:**
Abundio Romagosa, alias David, appealed a case where he was accused of the complex crime of
rebellion with murders, robberies, and kidnappings. The charges stemmed from his affiliation with
the Communist Party of the Philippines (CPP) and the Hukbong Mapagpalaya Ng Bayan (HMB),
also known as the Hukbalahaps (HUks). The information alleged his involvement in rebellious
activities, including murders committed as a means to further the rebellion.
He pleaded guilty to the charges, and the prosecution recommended a penalty of life imprisonment.
The lower court, however, sentenced him to suffer the penalty of reclusion perpetua, pay a fine,
indemnify the heirs of those killed, and cover the costs.
**Issue:**
Whether Abundio Romagosa should be convicted of the complex crime of rebellion with murders,
robberies, and kidnappings or only of simple rebellion.
**Ruling:**
The decision was modified, and Romagosa was convicted of the crimes of simple rebellion and
murder. The court held that the crimes of murders, robberies, and kidnappings committed as a
means to or in furtherance of the rebellion are absorbed by and form part of the rebellion. As a
result, the court found the lower court erred in convicting Romagosa of the complex crime and
imposed sentences for simple rebellion and murder. He was sentenced to 8 years of prison mayor
for rebellion and an indeterminate sentence for murder. He was also ordered to pay fines, indemnify
the heirs, and cover the costs. Justices Montemayor, Labrador, Endencia, and Padilla dissented,
maintaining their views expressed in previous cases.
JUDGE ADORACION G. ANGELES, Petitioner,
vs.
HON. MANUEL B. GAITE, Acting Deputy Executive Secretary for Legal Affairs; HON. WALDO
Q. FLORES, Senior Deputy Executive Secretary, Office of the President; Former DOJ
SECRETARY HERNANDO B. PEREZ (now substituted by the Incumbent DOJ Secretary RAUL
GONZALES); Former PROV. PROS. AMANDO C. VICENTE (now substituted by the Incumbent
PROV. PROS. ALFREDO L. GERONIMO); PROS. BENJAMIN R. CARAIG, Malolos, Bulacan;
and MICHAEL T. VISTAN, Respondents.
**Facts:**
Judge Adoracion G. Angeles filed a Petition for Review, under Rule 43 of the 1997 Rules of Civil
Procedure, against the February 13, 2004 Decision and September 16, 2004 Resolution of the Court
of Appeals (CA) in CA-G.R. SP No. 76019. The case involves her grandniece Maria Mercedes
Vistan, whom she fostered for nine years. A falling out occurred with Michael Vistan, the half-brother
of Maria, leading to Maria leaving Judge Angeles' custody. Michael, in conspiracy with others,
induced Maria to leave. A kidnapping complaint was filed against Michael and others. Later, a
complaint for child abuse was filed against Michael. The Department of Justice (DOJ) dismissed
certain charges. The CA upheld the dismissal, and this petition ensued.
**Issue:**
1. Whether the reliance on Memorandum Circular No. 58 by the Office of the President is valid.
2. Whether the dismissal of the complaint for violation of Section 1(e) of PD No. 1829 against
Michael Vistan is proper.
3. Whether the dismissal of the complaint for violation of RA No. 7610 against Michael Vistan is
proper.
**Ruling:**
1. The Court affirmed the CA's decision, stating that Memorandum Circular No. 58, which limits the
review of DOJ decisions by the Office of the President, is a valid regulation and aligns with the
doctrine of qualified political agency. The President's delegation of authority to the Secretary of
Justice is within the bounds of the Constitution.
2. The Court agreed with the CA that the charge of obstruction of justice (Section 1(e) of PD No.
1829) was not warranted. The CA held that failure to serve a warrant on the accused doesn't amount
to obstruction of justice. The Court concurred, emphasizing the need for a clear statutory basis and
the liberal construction of penal statutes in favor of the accused.
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee,
vs.
GRACIANO L. CABRERA, ET AL., defendants-appellants.
FACTS:
In December 1920, a series of events unfolded in Manila, Philippines, leading to a violent uprising
involving members of the Constabulary against the city police. The initial spark was the arrest of a
woman, a member of a Constabulary soldier's household, by Manila policemen. This incident
escalated tensions between the two groups.
The following day, a confrontation between a policeman named Artemio Mojica and Constabulary
soldiers resulted in the shooting of a Constabulary soldier named Macasinag. This event fueled
resentment among the soldiers, leading to a desire for revenge against the Manila police. Rumors
circulated, contributing to a movement for reprisal by Constabulary soldiers.
On December 15, 1920, Constabulary soldiers, under the command of their sergeants and
corporals, initiated an armed attack on the Manila police force. The violence included shooting at
policemen, attacking a streetcar, and targeting specific police officers. The uprising resulted in
several deaths and injuries among civilians and police officers.
STATEMENT OF THE CASE AND OF THE FACTS:
The accused Constabulary soldiers were charged with sedition and murder. Seventy-seven
defendants confessed to participating in the uprising, stating that they sought revenge for perceived
abuses by the Manila police. The confessions were admitted as evidence.
The trial court found the defendants guilty of sedition, conspiracy, and violation of the Treason and
Sedition Law. The court imposed various penalties, including imprisonment and fines, based on the
level of participation and rank of each defendant.
ISSUES:
1. The admission of the confessions (Exhibits C to C-76) as evidence.
2. The existence of a conspiracy among the accused.
3. The conviction of the accused for violating the Treason and Sedition Law.
RULINGS:
1. The trial court did not err in admitting the confessions as evidence. The confessions were deemed
freely and voluntarily made, and the defendants' objections lacked merit.
2. The trial court did not err in finding a conspiracy among the accused. Even though the accused
claimed they acted individually, evidence pointed to a shared purpose of seeking revenge against
the Manila police.
3. The trial court did not err in convicting the accused of violating the Treason and Sedition Law. The
law does not distinguish between private citizens and government officials as offenders, and the
actions of the accused constituted sedition.
JUDGEMENT:
The trial court's judgment was affirmed. The accused were found guilty of sedition and sentenced to
various penalties, including imprisonment and fines. The court emphasized the gravity of the crime
and the need to hold the defendants accountable for their actions.
3. The Court upheld the dismissal of the child abuse complaint under RA No. 7610, stating that the
provincial prosecutor and the Secretary of Justice did not act with grave abuse of discretion. The
determination of probable cause during a preliminary investigation is an executive function, and the
reliance on the victim's affidavit, in this case, was not deemed as grave abuse of discretion.
In summary, the CA's decision to dismiss the petition was affirmed on all grounds.