GR 1513; (February, 1904) (Digest)
G.R. No. 1513 : February 12, 1904
THE UNITED STATES, complainant-appellee, vs. CASIANO SADIAN, defendant-appellant.
FACTS:
The provincial fiscal of Ilocos Norte filed an information charging Casiano Sadian and others with having formed a secret political society called “Kanayouan” in the latter part of June and early July 1903. The society’s purpose was to obtain Philippine independence through insurrection and rebellion against the Government of the United States in the Islands, in violation of Act No. 292 . During trial, witness Ariston Umayam testified that on July 5, 1903, Casiano Sadian made an incision in his forearm, wrote Umayam’s name with the blood, and told him he was to defend his country and fight the Americans. Umayam stated this was done while he was surrounded by the accused, who were armed. He further testified about a similar incident involving another individual, Gavino Umayam, the following day. The accused, Casiano Sadian, pleaded not guilty, denying Umayam’s account and claiming the incision ceremony was a sign of fraternity for a political election purpose. Other accused individuals testified they joined a party and took an oath to defend the country but denied involvement in or knowledge of the forced incisions. Only Casiano Sadian appealed the lower court’s judgment.
ISSUE:
Whether the defendant-appellant, Casiano Sadian, is guilty of organizing and participating in a secret political society for the purpose of rebellion, as defined and punished under Section 9 of Act No. 292 .
RULING:
Yes. The Supreme Court found the evidence of Casiano Sadian’s guilt more than sufficient. The facts established that he was one of the organizers of the secret political society “Kanayouan” and actively engaged in procuring members with the criminal intent of fomenting rebellion against the government. These acts fall squarely within the provisions of Section 9 of Act No. 292 . The Court held that the facts did not constitute the crime of conspiracy under Section 4 of the same Act, as no such conspiratorial act was committed. Accordingly, the judgment of the lower court was reversed with respect to Sadian. He was convicted and sentenced to one year’s imprisonment and 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 one-fifth of the costs.