G.R. No. 1503, March 14, 1905
THE UNITED STATES, complainant-appellee, vs. ALEJO RAVIDAS, ET AL., defendants-appellants.

FACTS:
A complaint charged twenty-five defendants with the crime of insurrection. The Court of First Instance acquitted five defendants and convicted the remaining twenty, imposing varying prison sentences. All twenty convicted defendants appealed. During the appeal, eight defendants withdrew their appeal, and another ten escaped from provincial jail. Consequently, the appeal proceeded only for the two remaining appellants, Alejo Ravidas and Narciso Melliza. The evidence against Ravidas, the municipal president of Agusan, showed only that he knew insurgents were in his jurisdiction but failed to report this to provincial authorities or take any action against them. The evidence against Melliza showed only that he sold rice to persons who later turned out to be insurgents, with no proof he knew they were insurgents or intended to aid the insurrection.

ISSUE:
Whether the acts or omissions proven against appellants Alejo Ravidas and Narciso Melliza constitute the crime of insurrection as defined by law.

RULING:
No. The Supreme Court reversed the judgment of conviction against Alejo Ravidas and Narciso Melliza and acquitted them. The Court held that Ravidas’s omission or failure to report the presence of insurgents, while reproachable, is not an act enumerated and punishable as insurrection under Act No. 292. For Melliza, the mere act of selling rice to persons who were later discovered to be insurgents, without proof that he knew they were insurgents or sold the rice with the deliberate purpose of aiding the insurrection, does not constitute the crime. The appeal was dismissed as to the ten defendants who escaped, which the Court deemed a withdrawal of appeal, and the lower court’s judgment against them was affirmed.