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Crim2 Case Digest Format
Crim2 Case Digest Format
Crim2 Case Digest Format
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 subtract from obedience to the government or its laws, a part or all of the Filipino territory
objective is to obtain the absolute independence of the Philippines before the end or some body of the armed force, or strip the Chief Executive, or the Legislature of some
of 1935. or all of its prerogatives or its powers.
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 Rebellion and non-issuance is how the crime committed by the appellant must
the municipality of Sta. Rosa, Laguna with the border towns and with Manila properly be described, because rebellion is, according to article 134 of the Revised
were cut off, the electric lighting turned off and the houses closed. Criminal Code:
4. The armed people on the roads stopped the passage of vehicles, requisitioning the
passengers and snatching the weapons they were carrying. "to rise publicly and take up arms against the Government in order to subtract the
5. Several Sakdalistas, armed with bands, flags and a variety of weapons obedience of it, or its laws, the Filipino territory or part of it, or some body of land troops
marched in groups to seize the municipal building of Sta. Rosa to subtract or sea or any other kind of armed force, or to dispossess all or part of the Chief Executive
said municipality from obedience to the duly constituted government. or the co-legislators of their prerogatives or faculties. "
6. During the incident, there was a bloody encounter between these Sakdalists and
the constabularies that were sent to restore order. The purposes of Sedition, according to article 139 of the Revised Criminal Code,
7. The Sakdalists stopped several vehicles and one of them was that of a lawyer which remains the same because the amendments introduced in Commonwealth Law No.
named Feliciano Gomez, who at that time was with his family. 217, which entered into force one year after the Car crime:
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. 1. Prevent the enactment of the laws, the execution of the same, or the celebration of
9. Gomez recognized League because the latter was the former’s childhood a popular election;
companion and the driver Damian Hernandez also saw him that occasion armed
with shotgun at a distance of 10 meters from the vehicle. 2. Prevent the Insular Government or any provincial or municipal government or its
10. Appellant League’s alibi was that during the incident, he was in Manila. But he officials from exercising their functions or fulfilling them of any administrative order;
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 3. To exercise any act of hatred or revenge on the person or property of any public
part in the uprising according to the testimonies of Feliciano Gomez, Damian official or employee;
Hernandez, and Ricardo Mendoza.
11. Appellant Jose League requests that the decision of the CA confirming the 4. To exercise with any political or social purpose1 any act of hatred or revenge
decision of the CFI of Laguna finding him guilty of the crime of rebellion be against individuals or any social class; and
revised.
5. To deprive, with a political or social purpose, of all or a part of their property to any
ISSUE/S: person, the municipality, the province or the island or United States governments. "
W/N the crime of rebellion is the proper crime to be imposed in this case (YES) 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.
RATIO:
On the other hand, Rebellion is more apt as there was an armed public uprising by the
Issue 1: YES. members of the Sakdalista partylist, with the objective to seize the municipal building of
It is not the greater of lesser extent of territory in which an armed public uprising takes Sta. Rosa to subtract said municipality from obedience to the duly constituted government.
place and develops against the government, which determines its nature of rebellion or This is in accordance to “dispossess all or part of the Chief executive or co-legislators of
sedition, but the end that with that uprising is sought. their prerogratives or faculties.” Thus, Rebellion is the proper crime.
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