G.R. No. 6867 , December 23, 1911
THE UNITED STATES, plaintiff-appellee, vs. MAXIMINO PLANAS, defendant-appellant.

FACTS

Maximino Planas, the duly elected municipal president of Bambang, Nueva Vizcaya, was charged with the crime of conspiring to commit sedition. The complaint alleged that on or about September 1, 1910, in Bambang, he conspired to rise publicly and tumultuously to inflict acts of hate or revenge upon government officials and certain individuals, to despoil property with a political or social object, and uttered seditious words. After trial, the court found him guilty based on witness testimonies. The evidence showed that on September 3 and 4, 1910, Planas assembled the town policemen and councilmen, informed them that insurgents had taken Solano, and instructed them to surrender their arms to him, prepare other weapons, and be ready to join the insurgents upon their arrival in Bambang to kill two Americans (Bennett and Scott) and a Roman Catholic priest, and burn the convent. He was sentenced to three years imprisonment, a P1,000 fine, with subsidiary imprisonment in case of insolvency, and costs.

ISSUE

1. Whether the complaint was defective.
2. Whether the evidence was sufficient to prove the defendant’s guilt beyond reasonable doubt.

RULING

1. On the defective complaint: The Supreme Court held that the objection to the sufficiency of the complaint cannot be raised for the first time on appeal, as no such objection was made in the trial court. The Court cited a line of precedents establishing this rule.
2. On the sufficiency of evidence: The Supreme Court affirmed the trial court’s findings of fact, holding that the evidence conclusively and overwhelmingly proved the defendant’s guilt beyond reasonable doubt. The testimonies of the policemen, councilmen, and municipal officials consistently established that Planas, as municipal president, actively conspired to join a seditious uprising and incited others to do so, with the intent to commit violent acts against government officials and individuals.
The sentence of the lower court was affirmed in its entirety.