G.R. No. L-2317

FACTS:
Appellants Francisco Balbas and Ignacio Flores, employees of Compañia Tabacalera in Isabela, were convicted under Section 3 of Act No. 292 for giving aid and comfort to an armed group under Manuel Tomines and a deserter named Sibley, which was in open insurrection against the U.S. and Philippine Government in 1903. The evidence established that the appellants furnished provisions (rice, salt, vino) from the company’s warehouse to the armed band, allegedly to secure its goodwill and prevent molestation of company property and personnel.

ISSUE:
Whether the appellants are guilty of the crime defined under Section 3 of Act No. 292 , which requires that the aid or comfort be given to persons one knows are engaged in “rebellion or insurrection” against the authority of the U.S. or the Government of the Philippine Islands.

RULING:
No. The Supreme Court reversed the conviction and acquitted the appellants. While the evidence proved that the appellants gave aid to the armed band and knew its members were evildoers united for an unlawful purpose, it did not establish beyond a reasonable doubt that the appellants had specific knowledge that the band’s purpose was rebellion or insurrection as statutorily defined. The known facts were also consistent with the band being mere brigands or engaged only in sedition against local authorities. Since guilty knowledge of the specific crime of rebellion or insurrection is an essential element of the offense under Act No. 292 , and the prosecution failed to prove it conclusively, the appellants must be acquitted.