GR 1481; (February, 1904) (Digest)
G.R. No. 1481 : February 17, 1904
THE UNITED STATES, complainant-appellee, vs. LIBERATO EXALTACION and BUENAVENTURA TANCHINCO, defendants-appellants.
FACTS:
On March 26, 1903, the Provincial Fiscal of Bulacan filed an information charging Liberato Exaltacion and Buenaventura Tanchinco with the crime of rebellion. The charge alleged that after November 4, 1901, they willfully bound themselves to participate in a rebellion against the Government of the United States by swearing allegiance to the Katipunan Society, which aimed to overthrow the government by force of arms.
The prosecution’s evidence consisted primarily of two documents in Tagalog, dated July 4 and July 17, 1902, containing oaths of allegiance and a covenant to obey the orders of the Katipunan until death in defense of the country. These documents, bearing the signatures of the accused, were captured by police from an encampment of the bandit leader Contreras. When confronted, the defendants admitted signing the documents but claimed they did so under compulsion and fear of death while being held captive by armed men belonging to Contreras’s band. They testified that upon their release, they immediately reported the incidents to the municipal president of Meycauayan, Tomas Testa, and later to a lieutenant of the volunteers. Several witnesses corroborated the defendants’ accounts of their capture and their subsequent reports to the authorities.
ISSUE:
Whether the guilt of the defendants for the crime of rebellion has been proven beyond a reasonable doubt, considering their defense of having signed the incriminating documents under duress while captives of a bandit group.
RULING:
The Supreme Court REVERSED the judgment of the lower court and ACQUITTED the defendants. The Court held that the evidence for the prosecution was insufficient to prove guilt. The facts established that the defendants were kidnapped by brigands and signed the documents under compulsion while in captivity, which relieved them of criminal liability for rebellion. Their conduct in promptly reporting the matter to local authorities upon release strongly corroborated their testimony and demonstrated their innocence. The guilt of the defendants under Act No. 292 was not established beyond a reasonable doubt.