GR L 29814; (March, 1969) (Digest)
G.R. No. L-29814 March 28, 1969
SANTOS ANDAL, ET AL., petitioners, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioners, including the widower Teofilo Cal, were members of the Jehovah’s Witnesses sect. In September 1958, Dorotea Bosque, wife of Teofilo Cal, died. The petitioners, using a death certificate (Exhibit 1-C) that indicated the Catholic cemetery of Manguiring, Calabanga, Camarines Sur as the place of burial, proceeded to inter her remains in that Catholic cemetery. The cemetery, though subject to a land title dispute between the Catholic Church and a private claimant, was in the possession of the Church at the time. The parish priest had previously prohibited the burial. The Court of Appeals found that the petitioners did not act out of strict necessity but rather through a preconceived plan to assert superiority over the priest and the Catholic Church. They allegedly employed force, threatened the priest, deceived the cemetery caretaker, and conducted their sect’s rites (singing hymns) within the cemetery. They were originally charged with “offending religious feelings” under Article 133 of the Revised Penal Code. The Court of Appeals modified the lower court’s judgment and convicted them of the lesser crime of “unjust vexation” under Article 287(2) of the Revised Penal Code, sentencing each to 30 days of arresto menor and a fine.
ISSUE
Whether or not the petitioners could be validly convicted of the crime of unjust vexation under an information charging them with offending religious feelings.
RULING
Yes. The Supreme Court denied the petition for certiorari and the subsequent motion for reconsideration, thereby upholding the conviction for unjust vexation. The Court acknowledged that, in principle, a legal duty exists for a survivor to bury the deceased within a definite period, and if there were only one cemetery, performing that duty might not be criminal. However, the Court respected the factual findings of the Court of Appeals, which established that the petitioners did not act out of pure necessity but through a deliberate plan involving the employment of force and defiance of legal norms. Since they took the law into their own hands, their claim to the protection of the law (based on performing a legal duty) could not be sustained. The rule of law would be meaningless if such acts were condoned. Therefore, no judicial relief could be granted to the petitioners.