People v.

Bautista, de
Guzman, and Puzon (6 Phil.
581)
Jeremy B Quimeniano
Crim3B
 Facts of the Case:
● The appellants, Francisco Bautista, Aniceto de Guzman,
and Tomas Puzon, were convicted in the Court of First
Instance of Manila for conspiracy to overthrow the
Government of the United States in the Philippine Islands.
The conspiracy aimed to establish a government known as
the Republica Universal Democratica Filipinos. The charges
were brought under section 4 of Act No. 292 of the
Philippine Commission.
 Facts of the Case:
● The conspiracy was organized by Filipinos residing in
Hongkong, with Prim Ruiz as the titular head and Artemio
Ricarte as the military chief. Ricarte, hiding on the steamship
Yuensang, arrived in Manila and conducted meetings to
perfect the plans. Bonds were issued, and commissions as
officers in the revolutionary army were granted to various
conspirators.
 Facts of the Case:
● Francisco Bautista, a resident of Manila and a friend of
Ricarte, was proven to be present at meetings where conspiracy
plans were discussed. Bautista secretly sent 200 pesos to aid
Ricarte. Tomas Puzon, through R. Muñoz, a prime leader of the
movement, accepted a commission as brigadier-general of the
signal corps in the revolutionary forces. Puzon allegedly
assured Muñoz that he had things in readiness for the
insurrection.
 Facts of the Case:

● Aniceto de Guzman's conviction was based on his

acceptance of bonds prepared by conspirators to raise
funds for the conspiracy.
●
ISSUES:
Conspiracy and Overt Acts: The appellants were charged with conspiracy to overthrow
the government. The evidence presented included meetings, issuance of bonds, and
appointments as officers in the revolutionary army. The key question was whether
accepting such appointments constituted overt acts of conspiracy.
● Confession of Tomas Puzon: Puzon's written statement at the time of his arrest
contradicted his later claim that he never intended to fulfill the obligations of the
appointment. Puzon's defense relied on the argument that he accepted the position as a
joke and out of friendship.
● Possession of Bonds by Aniceto de Guzman: De Guzman's conviction was based on the
possession of bonds, and the question was whether he had knowledge of the conspiracy
and willingly participated.
● Application of Constitutional Provision: The defense argued that the constitutional
provision requiring the testimony of at least two witnesses did not apply to the crime of
conspiring to commit treason.
 RULING:

The Court affirmed the conviction of Francisco Bautista and Tomas

Puzon but reversed the conviction of Aniceto de Guzman. It
distinguished this case from previous ones by highlighting that
Puzon voluntarily accepted the appointment and assumed the
obligations implied by it, making it relevant as evidence of his
criminal relations with the conspirators.

The Court rejected the application of the constitutional provision requiring two
witnesses for treason, emphasizing that conspiracy to commit treason is a
separate offense
The judgment imposed subsidiary imprisonment, which had no legal basis, and
was reversed for Bautista and Puzon..
 Conclusion:

The case report highlights the Court's careful consideration of the evidence presented,
particularly in establishing the voluntary acceptance of appointments as evidence of
involvement in the conspiracy. It clarifies the distinction between the crimes of conspiracy and
treason, emphasizing the applicability of specific legal provisions in each case.
US v. FRANCISCO BAUTISTA ET AL.
(lawyerly.ph)