GR L 1591; (December, 1904) (Digest)
G.R. No. L-1591, December 28, 1904
THE UNITED STATES, complainant-appellee, vs. INOCENCIO DAYUTAL, defendant-appellant.
FACTS:
The defendant, Inocencio Dayutal, was charged with the crime of insurrection. Four prosecution witnesses testified that during January and February 1903, they were sequestered by an insurgent band led by Ciriaco Contreras and saw Dayutal among the armed members of the band in the mountains. One witness, a Constabulary private captured during an encounter on January 22, 1903, identified Dayutal as one of the combatants who took him prisoner. The defense attempted to establish an alibi, claiming Dayutal was working at a quarry in Meycauayan during those months. However, the alibi evidence was deemed inconclusive, as no witness could attest to his daily presence at the quarry, and the quarry owner’s records were based on hearsay and were properly excluded by the trial court for lack of authenticity. The defense also presented testimony alleging that prosecution witnesses had recanted their earlier statements out of fear, but this was found unsubstantiated and irrelevant to the testimony given at trial.
ISSUE:
Whether the evidence presented is sufficient to convict Inocencio Dayutal of the crime of insurrection under Section 3 of Act No. 292 .
RULING:
Yes. The Supreme Court affirmed the judgment of conviction. The testimony of the prosecution witnesses was credible, consistent, and sufficient to establish Dayutal’s active participation in the insurgent band led by Ciriaco Contreras during the relevant period. The defense’s alibi was weak and uncorroborated, and the evidence offered to impeach the prosecution witnesses was deemed unreliable. The facts constituted the crime of insurrection as defined by law. The penalty imposed by the trial courtfour years’ imprisonment and a fine of two thousand dollarswas in accordance with Act No. 292 . The appealed judgment was affirmed with costs against the appellant.
