G.R. No. L-5796; August 29, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff and appellee, vs. GUILLERMO CAPADOCIA, ET AL., defendants, JOSE MA. NAVA, ALFREDO PALMEJAR, MIGUEL ELEVADO and NAPOLEON NAVA, defendants and appellants.

FACTS

Alfredo Palmejar, along with numerous others, was charged in the Court of First Instance of Iloilo with the complex crime of rebellion with multiple murder, arson, kidnapping, robbery, and physical injuries. Palmejar, the national treasurer of the Federacion Obrera de Filipinas (FOF) and son-in-law of co-accused Jose M. Nava (FOF national president), pleaded not guilty. After trial, he was convicted of simple rebellion. The prosecution’s theory was that the FOF was a “front” for the Hukbong Mapagpalaya ng Bayan (HMB/Hukbalahap) and that Palmejar participated in its criminal purposes by supplying money and mimeographing its publications. The evidence against him consisted mainly of the testimonies of confessed Huks Pedro Torres Ternura, Rodrigo de Jesus, and Placido Menaje, and a letter (Exhibit QQ-4) from Huk leader Guillermo Capadocia mentioning Palmejar. Ternura testified that in November 1949 he saw Palmejar mimeographing a Huk publication at the FOF office and that in June 1950, Palmejar gave him and two companions P25.00 and a guide to attend a Huk school in Lambunao. The defense highlighted that Ternura had a personal grievance against Palmejar, having been dismissed from the FOF in August 1949 for misappropriating union funds. Furthermore, on January 4, 1950, Palmejar had moved for and secured the expulsion of Guillermo Capadocia from the FOF through a published resolution, denouncing Capadocia’s actions as contrary to the government and the FOF’s constitution.

ISSUE

Whether the guilt of Alfredo Palmejar for the crime of rebellion has been proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the judgment of conviction and acquitted Alfredo Palmejar. The Court found the evidence against him insufficient and unreliable. The testimony of Rodrigo de Jesus was discounted based on a prior ruling questioning his credibility. The testimony of Placido Menaje was hearsay and based on a mistaken identification. The testimony of Pedro Torres Ternura, the principal witness, was uncorroborated, came from a biased source (a detained confess Huk whose cooperation could affect his fate), and was motivated by a personal grievance arising from his dismissal by Palmejar. The letter Exhibit QQ-4 was inadmissible as an act of a conspirator because there was no independent evidence proving Palmejar’s participation in a conspiracy to commit rebellion. The Court also found Palmejar’s active role in expelling Capadocia from the FOF in January 1950 to be inconsistent with the allegation that he was aiding Capadocia’s Huk movement in June 1950. Consequently, his guilt was not established beyond reasonable doubt.