GR 35686; (October, 1932) (Digest)
March 10, 2026GR 36278; (October, 1932) (Digest)
March 10, 2026G.R. No. 36277; October 26, 1932
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. CRISANTO EVANGELISTA and ABELARDO RAMOS, defendants-appellants.
FACTS
The accused, Crisanto Evangelista and Abelardo Ramos, were charged with violating section 8 of Act No. 292, as amended (the sedition law). On May 1, 1931, a communist parade in Caloocan was prevented after its permit was revoked. When allowed by a Constabulary officer to inform the crowd to disperse, Evangelista instead made a speech claiming persecution by authorities, inciting the crowd. Shouts of “Let us fight them” were heard, with Ramos specifically shouting “Let us fight them until death.” The crowd then advanced against the Constabulary soldiers, who had to use a water pump to disperse them. The trial court found the accused guilty.
ISSUE
Whether the statements and actions of the accused constituted the crime of sedition.
RULING
Yes, the judgment of the trial court is affirmed. The accused’s utterances under the circumstances were clearly seditious. The statements were not a mere petition for redress of grievances but an inducement to fight and resist authorities, inciting actual disorder and an advance against law enforcement. This differed from the peaceful assembly in United States vs. Apurado. The act was a practical expression of instigation to overthrow the government, fitting the definition of sedition.
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