G.R. No. 1988 : April 3, 1905
THE UNITED STATES, plaintiff-appellee, vs. MARCELO CAPARAS, ET AL., defendants-appellants.

FACTS:
The six defendants were charged with the crime of sedition for being members of the secret society “Santa Iglesia.” The complaint alleged that the society’s purposes were seditious, aiming to disturb peace and order in Nueva Ecija, and that its members committed acts of hatred and revenge against government officials and wealthy inhabitants. Specifically, it was alleged that in September 1903, the defendants, along with other members and the society’s organizer Felipe Salvador, held a meeting in Talavera to formally organize and foment sedition. Following this, a band of over a hundred armed men attacked the Constabulary cuartel in San Jose on September 16, 1903, resulting in the death and wounding of several Constabulary soldiers and the seizure of firearms and ammunition. The defendants were convicted by the trial court and sentenced to imprisonment.

ISSUE:
Whether the defendants are guilty of the crime of sedition as members of the “Santa Iglesia” society.

RULING:
The Supreme Court modified the decision of the trial court. It found that while the evidence did not conclusively prove the defendants’ direct participation in the attack on the San Jose cuartel, their membership in the “Santa Iglesia” was fully proven through their own sworn confessions before the justice of the peace, which were corroborated by witnesses. The Court rejected the defendants’ claim that their confessions were extracted through torture and threats, as this was offset by the counter-proof presented by the prosecution. The “Santa Iglesia” was determined to be a secret society with seditious objectives aimed at promoting rebellion. Consequently, the defendants were found guilty under Section 9 of Act No. 292 (the Sedition Law) for belonging to a secret society organized for seditious purposes. The penalties imposed by the lower court were reversed. The defendants were each sentenced to one year’s imprisonment, a fine of P1,000, and proportionate shares of the costs.