PEOPLE v.

SIYOH (1986) FACTS:

141 SCRA 356
1. This is an automatic review of the CFI of Basilan imposing death penalty to
G.R. No. L-57292| February 18, 1986| Qualified Piracy | Justice Abad Santos | Peliño accused Siyoh, et al. for the crime of Qualified Piracy with triple murder and
frustrated murder.
Petitioner: People of the Philippines
2. Businessman Aurea engaged gave goods with 18,000php worth to victim-
Respondents: Julaide Siyoh, Omar-Kayam Kiram, Namli Indanan, and Andaw Jamahali
survivor Antonio De Guzman, victims Danilo Hiolen, Rodolfo De Castro, and
Anastacio de Guzman, with the agreement that the group will sell them, pay back
Recit-Ready:
the value of the goods, and keep the profits for themselves.
Victims Danilo Hiolen, Rodolfo De Castro, and Anastacio de Guzman, had an agreement
3. The group stayed at accused Omarkayam Kiram’s house for 2 nights in Pilas
with a certain Aurea that the group will sell Aurea’s goods worth 18,000php, pay back the
Island.
value of the goods, and keep the profits for themselves. The group stayed at the accused
4. For 2 days, the group together with accused Kiram and Siyoh started selling the
Kiram’s house for two nights in Pilas Island. They were able to earn 18,500 in two days
goods and we’re able to sell 15,500php and 3,000 worth on respective days.
in Baluk-Baluk Island, both days they were accompanied by the 2 accused. Witness-
5. Kiram and Siyoh were seen by the Antonio talking with 2 persons whose faces
survivor Antonio saw Kiram and Siyoh talking to 2 armed-looking men near a dilapidated
the group saw but could not recognize.
house in Baluk-Baluk. After selling the goods, the group with Kiram and Siyoh decided
6. After selling the goods, the group with Kiram and Siyoh decided to go back to
to go back to Pilas Island. On their way, Antonio saw another pump boat painted green
Pilas Island.
and red moving towards them, Kiram then turned off the engine of the pump boat. Two
7. On their way, Antonio De Guzman saw another pump boat painted green and red.
shots were fired from the other boat. Antonio recognized the two persons on the other
8. Kiram turned off the engine of their pump boat. Two shots were fired from the
pumpboat to be the same persons the accused were talking to. The accused told the victims
other pump boat as it moved towards them.
to undress. Siyoh hacked Hiolen while Kiram hacked de Castro. Antonio De Guzman
9. Antonio De Guzman recognized the two persons on the other pump boat to be the
jumped into the water. As he was swimming away from the pump boat, the two strangers
same persons Kiram and Siyoh were talking to.
fired at him injuring his back. He was able to reach a mangrove and stayed there until
10. The group were divested of their money and their goods by Kiram.
nightfall. After leaving the mangrove, he saw the dead bodies of his companions. He was
11. Kiram and his companions also ordered the group to undress. Kiram took
picked up by a fishing boat and was brought to Philippine Army Station to be treated with
Antonio’s pants.
first aid and later on moved to a hospital. While waiting for the bodies of his companions,
12. With everybody undressed, Kiram said, ‘It was good to kill all of you.’ After that
Antonio saw the 2 accused in the wharf and pointed at them to the police officer. The
remark, Siyoh hacked Hiolen while Kiram hacked de Castro.
accused were arrested then and there. They were proven guilty of the crime of Qualified
13. Antonio De Guzman jumped into the water. As he was swimming away from the
Piracy with triple murders and frustrated murder by the CFI of Basilan. The accused are
pump boat, the two strangers fired at him injuring his back. He was able to reach
assailing that the CFI erred in finding them guilty. The issue is w/n the CFI erred in
a mangrove where he stayed ‘till nightfall.
holding them guilty for the crime charged. The Court held in the negative. Conspiracy in
14. When he left the mangrove, he saw the dead bodies of Anastacio de Guzman,
this case was proved: (1) Antonio saw the accused talking with 2 armed-looking men; (2)
Danilo Hiolen, and Rodolfo De Castro.
Antonio recognized the two strangers on the other pumpboat to be the same armed-looking
15. He was picked up by a fishing boat and brought to the Philippine Army station
men the accused were talking to; (3) the accused did not receive orders from transferred
where he received his first aid treatment. Later he was brought to J.S. Alano
the unsold goods; (4) Antonio and companion peddlers were divested of their jewelries
Memorial Hospital in Basilan.
and cash and undressed while the 2 accused remained unharmed or unmolested. That even
16. On July 15, while waiting for the dead bodies of his companions at the wharf, de
though Anastacio’s body was not yet found is immaterial in this case.
Guzman saw Siyoh and Kiram. He pointed them out to the PC and the 2 were
arrested before they could run.
Doctrine:
17. They were proven guilty by the trial court. On appeal, Siyoh and Kiram were
The number of persons killed on the occasion of piracy is not material. P.D. 532 considers
assailing that the lower court erred in finding them guilty beyond reasonable
qualified piracy, i.e. rape, murder, or homicide is committed as a result or on the occasion
doubt of the crime charged.
of piracy, as a special complex crime punishable by death regardless the number of
victims.
ISSUE/S:
W/N the trial court erred in finding the accysed guilty of Qualified Piracy with triple
Petitioner: Jose League
murder and frustrated murder (NO)
Respondents: People of the Philippines
RATIO:
Recit-Ready:
Appellant Jose League was the general treasurer of the Sakdalista partylist whose
Issue 1: NO.
objective is to obtain the absolute independence of the Philippines before the end of 1935.
The trial court which had the opportunity of observing the demeanor of the witnesses
On May 2, 1935, armed Sakdalistas stopped several vehicles and one of those vehicles is
and how they testified assigned credibility to Antonio de Guzman’s testimony and the
owned by lawyer named Feliciano Gomez who at that time, was with his family. When
record does not reveal any fact or circumstance of weight and influence that would warrant
the automobile did not stop, it was shot by the Sakdalists and League was one of those
the reversal of the trial court’s determination.
armed persons who tried to stop Gomez’s car. Gomez recognized League because the
latter was the former’s childhood companion and the driver Damian Hernandez also saw
Conspiracy was proved. As Judge Rasul started—it is believed that conspiracy as
him that occasion armed with shotgun at a distance of 10 meters from the vehicle.
alleged in the information is sufficiently proved in this case. In fact the following facts
Appellant League’s alibi was that during the incident, he was in Manila. Such alibi was
appear to have been established to show clear conspiracy: (1) On July 14, while peddling,
not recognized by the court as he was identified one of those who took a direct part in the
the survivor witness (Antonio) noticed that near the window of a dilapidated house, both
uprising through the testimonies of Feliciano Gomez, Damian Hernandez, and Ricardo
accused were talking to 2 armed strange-looking men at Baluk-Baluk Island; (2) when the
Mendoza. Appellant is now requesting that the Court revises the decision of the CA
pumpboat was chased and overtaken, Antonio recognized the same 2 armed strangers to
finding him guilty beyond reasonable doubt of the crime of rebellion. The Court upheld
whole the accused talked to; (3) the two accused, without order from the 2 armed strangers
the decision of the CA saying that the crime of Rebellion imposed is proper in this case.
transferred the unsold goods to the captor’s banca; (4) Antonio and companion peddlers
It cannot be Sedition because under this particular crime, the objective should be (1) to
were divested of their jewelries and cash and undressed while the 2 accused remained
prevent the enactment, execution of laws, or celebration of a popular election; (2) to
unharmed or unmolested. These concerted actions on their part prove conspiracy and make
prevent the Insular Government or any provincial or municipal government or its officials
them equally liable for the same crime.
from freely exercising their functions or complying with any administrative order; (3) to
exercise for any act of hatred or revenge on the person or property of any official or public
That even though Anastacio’s body was not yet found is immaterial in this case. The
employee; (4) to exercise for any political or social purpose any act of hatred or revenge
number of persons killed on the occasion of piracy is not material. P.D. 532 considers
against individuals or any social class; or (5) to dispossess, for political or social purpose,
qualified piracy, i.e. rape, murder, or homicide is committed as a result or on the occasion
all or part of their property to any person, the municipality, the province or the island
of piracy, as a special complex crime punishable by death regardless the number of victims.
governments or the US. In this particular case, none of those enumerated under the crime
of Sedition apply in any of the facts given. On the other hand, Rebellion is more apt as
Decision is affirmed with the following modifications: (1) for lack of necessary votes,
there was an armed public uprising by the members of the Sakdalista partylist, with the
penalty imposed shall be reclusion perpetua, and (2) each of the appellants shall pay in
objective to seize the municipal building of Sta. Rosa to subtract said municipality from
solidum to the heirs of the deceased the indemnity of 30,000php.
obedience to the duly constituted government. This is in accordance to “dispossess all or
part of the Chief executive or co-legislators of their prerogratives or faculties.” Thus,
Rebellion is the proper crime.

Doctrine:
Rebellion according to Art. 134 of the RPC is "to rise publicly and take up arms
against the Government in order to subtract the obedience of it, or its laws, the Filipino
LEAGUE v. PEOPLE (1941)
territory or part of it, or some body of land troops or sea or any other kind of armed force,
141 SCRA 356
or to dispossess all or part of the Chief Executive or the co-legislators of their prerogatives
or faculties."
GR No. 47367| September 2, 1941| Rebellion v. Sedition | Justice Diaz| Peliño

FACTS:
 1. Appellant Jose League was the general treasurer of the Sakdalista partylist whose
objective is to obtain the absolute independence of the Philippines before the end
of 1935.
2. The Sakdalista planned an armed uprising in several provinces especially Laguna.
3. On the night of May 2, 1935, the telegraph and telephone wires that connected
the municipality of Sta. Rosa, Laguna with the border towns and with Manila
were cut off, the electric lighting turned off and the houses closed.
4. The armed people on the roads stopped the passage of vehicles, requisitioning the
passengers and snatching the weapons they were carrying.
5. Several Sakdalistas, armed with bands, flags and a variety of weapons
marched in groups to seize the municipal building of Sta. Rosa to subtract
said municipality from obedience to the duly constituted government.
6. During the incident, there was a bloody encounter between these Sakdalists and
the constabularies that were sent to restore order.
7. The Sakdalists stopped several vehicles and one of them was that of a lawyer
named Feliciano Gomez, who at that time was with his family.
8. When the automobile did not stop, it was shot by the Sakdalists and League was
one of those armed persons who tried to stop Gomez’s car.
9. Gomez recognized League because the latter was the former’s childhood
companion and the driver Damian Hernandez also saw him that occasion armed
with shotgun at a distance of 10 meters from the vehicle.
10. Appellant League’s alibi was that during the incident, he was in Manila. But he
no longer insists on such defense for having declared those Two tribunals that it
could not merit credit for having proven clearly the opposite, that he took direct
part in the uprising according to the testimonies of Feliciano Gomez, Damian
Hernandez, and Ricardo Mendoza.
11. Appellant Jose League requests that the decision of the CA confirming the
decision of the CFI of Laguna finding him guilty of the crime of rebellion be
revised.
ISSUE/S:
W/N the crime of rebellion is the proper crime to be imposed in this case (YES)
RATIO:
Issue 1: YES.
It is not the greater of lesser extent of territory in which an armed public uprising takes
place and develops against the government, which determines its nature of rebellion or
sedition, but the end that with that uprising is sought.
Rebellion has more transcendental purpose and its effects are more serious and more
pernicious for the government, than those of the sedition, because with it one wants to
subtract from obedience to the government or its laws, a part or all of the Filipino territory
or some body of the armed force, or strip the Chief Executive, or the Legislature of some
or all of its prerogatives or its powers.
Rebellion and non-issuance is how the crime committed by the appellant must
properly be described, because rebellion is, according to article 134 of the Revised
Criminal Code:
"to rise publicly and take up arms against the Government in order to subtract the
obedience of it, or its laws, the Filipino territory or part of it, or some body of land troops
or sea or any other kind of armed force, or to dispossess all or part of the Chief Executive
or the co-legislators of their prerogatives or faculties. "
The purposes of Sedition, according to article 139 of the Revised Criminal Code,
which remains the same because the amendments introduced in Commonwealth Law No.
217, which entered into force one year after the Car crime:
1. Prevent the enactment of the laws, the execution of the same, or the celebration of
a popular election;
2. Prevent the Insular Government or any provincial or municipal government or its
officials from exercising their functions or fulfilling them of any administrative order;
3. To exercise any act of hatred or revenge on the person or property of any public
official or employee;
4. To exercise with any political or social purpose1 any act of hatred or revenge
against individuals or any social class; and
5. To deprive, with a political or social purpose, of all or a part of their property to any
person, the municipality, the province or the island or United States governments. "
The acts executed by the appellant and his followers do not fit into any of those that
are listed in the aforementioned article that speaks sedition.
On the other hand, Rebellion is more apt as there was an armed public uprising by the
members of the Sakdalista partylist, with the objective to seize the municipal building of
Sta. Rosa to subtract said municipality from obedience to the duly constituted government.
This is in accordance to “dispossess all or part of the Chief executive or co-legislators of
their prerogratives or faculties.” Thus, Rebellion is the proper crime.