G.R. No. L‑2189

FACTS
– The appellants were tried in the Manila Court of First Instance for conspiring, under §4 of Act No. 292, to overthrow the United States Government in the Philippine Islands and to establish a “Republica Universal Democratica Filipina.”
– Evidence showed a 1903 Hong‑Kong‑based junta led by Prim Ruiz (political head) and Artemio Ricarte (military head). Ricarte entered Manila, held meetings, issued bonds, and appointed officers for a planned armed insurrection.
– Francisco Bautista (Manila resident) supplied Ricarte ₱200, attended the conspiratorial meetings, and affirmed that preparations were ready.
– Tomas Puzón was recruited by J.R. Muñoz, accepted the commission of brigadier‑general of the signal corps, and assured Muñoz that he had “things in readiness,” though he later claimed the acceptance was “joking.” His contemporaneous written statement admitted participation in the organization.
– Aniceto de Guzmán received bonds from conspirators but denied knowledge of the conspiracy; he claimed he destroyed the bonds upon discovering their contents.

The trial court sentenced Bautista to 4 years with hard labor and a ₱3,000 fine; Puzón and the others to 3 years with hard labor and ₱2,000 fines, plus a provision for subsidiary imprisonment upon default.

ISSUE
1. Whether the evidence sufficiently proved the guilt of each appellant for the crime of conspiracy to overthrow the government.
2. Whether the trial court’s imposition of subsidiary imprisonment for failure to pay fines was legally authorized.

RULING
– Bautista Conviction affirmed. The record shows his active assistance and participation in the conspiracy.
– Puzón Conviction affirmed. His written confession, corroborated by Muñoz’s testimony, established his acceptance of a revolutionary commission and readiness to act.
– De Guzmán Conviction reversed and the appellant acquitted. The prosecution failed to prove that he knowingly received or intended to use the bonds to further the conspiracy.
– The clause mandating subsidiary imprisonment for insolvent appellants was struck down for lack of statutory authority.

Accordingly, the judgment is modified: Bautista’s and Puzón’s sentences stand (minus subsidiary imprisonment), De Guzmán is released, and costs are adjusted as ordered.