GR 1615; (January, 1905) (Digest)
March 6, 2026GR 1536; (January, 1905) (Digest)
March 6, 2026G.R. No. 1643 : January 12, 1905
THE UNITED STATES, complainant-appellee, vs. SATURNINO DE LA CRUZ, ET AL., defendants-appellants.
FACTS:
The defendants were charged with the crime of insurrection. The Court of First Instance found all defendants guilty, sentencing Saturnino de la Cruz to eight years imprisonment and the others to five years. On appeal, the evidence showed that Saturnino de la Cruz confessed to being a colonel of the Katipuneros, an association organized to rebel against the U.S. Government, and identified his co-defendants as his soldiers. His confession was corroborated by the testimony of Dionisio Barretto, who stated that in January 1903, he was sequestered by Saturnino de la Cruz, Pio Quinto, and Gil Cervantes and forced to sign a document pledging to overthrow the government. Barretto also identified defendant Adriano Reyes as present during this incident. For the other defendants (Doroteo Calibio, Gaspar Aragon, Andres Maximo, and Jose Agustin), the only evidence was the un-corroborated confession of Saturnino de la Cruz and the fact that Doroteo Calibio was arrested in the company of Saturnino de la Cruz.
ISSUE:
Whether the evidence presented was sufficient to convict all defendants of the crime of insurrection.
RULING:
The Supreme Court affirmed the conviction of Saturnino de la Cruz, Gil Cervantes, Pio Quinto, and Adriano Reyes. Their guilt was sufficiently proved by the voluntary confession of Saturnino de la Cruz, corroborated by the testimony of Dionisio Barretto and the established seditious purpose of the Katipunan association. However, the Court reversed the conviction of Doroteo Calibio, Gaspar Aragon, Andres Maximo, and Jose Agustin. The evidence against themsolely based on the un-corroborated extrajudicial confession of a co-accused and, for Calibio, mere companionship at the time of arrestwas insufficient to prove guilt beyond reasonable doubt. They were acquitted. Costs were proportionally allocated.
