G.R. No. 1501 : April 16, 1904
THE UNITED STATES, complainant-appellee, vs. CANUTO BUTARDO, defendant-appellant.

FACTS:
On August 25, 1903, the provincial fiscal of Ilocos Norte filed a complaint against Canuto Butardo in the Court of First Instance. The accused was charged with administering and consenting to the administration of an oath, in violation of Act No. 292 . The information alleged that around the end of June or beginning of July 1903, Butardo, together with others, called meetings of inhabitants in the forests near Paoay. There, he administered an oath compelling persons to promise and swear to defend their native country against the Government of the United States in the Philippines and to keep the agreement secret. The ceremony included blindfolding, threats of death, and making incisions with a knife on the right arms of the participants. A document containing exhortations to defend the Philippines, for the revolution, independence, and death to traitors was found in the possession of an associate and was linked to Butardo as the author. The trial court convicted Butardo and sentenced him to six years imprisonment at hard labor, a fine of $5,000 gold, and costs. The defendant appealed.

ISSUE:
Whether the accused, Canuto Butardo, is guilty of the crime defined and punished under Section 12 of Act No. 292 for administering an oath for the purpose of disturbing the public peace or committing a criminal offense against the constituted government.

RULING:
Yes, the accused is guilty, but the penalty imposed by the trial court is modified. The Supreme Court found that the proven facts constitute the offense under Section 12 of Act No. 292 . The evidence established that Butardo, for the purpose of disturbing the public peace, compelled inhabitants by threats to take a secret oath and undergo a ceremony of incision, acts characteristic of revolutionary societies like the Katipunan. The document authored by Butardo, urging defense of the native land and revolution, corroborated the seditious purpose of the oath. The Court rejected Butardo’s defense that the oath was for a lawful electoral society, finding such secret proceedings with bloodletting inconsistent with legitimate election practices and indicative of a revolutionary character aimed at opposing the government.

However, the Supreme Court held that the trial court erred in convicting Butardo of the complex crime of conspiracy. The proper conviction should be for the specific act of administering a seditious oath as defined by the statute. Consequently, the judgment was reversed. The accused was sentenced to suffer imprisonment for one year, to pay a fine of 2,000 insular pesos, with subsidiary imprisonment in case of insolvency (not to exceed one-third of the principal penalty), and to pay the costs of both instances. The case was remanded to the trial court for execution.