US v. Bautista GR No. 2189 (1906) - Digest

US v. FRANCISCO BAUTISTA, ET.AL.
G.R. NO. 2189 | November 03, 1906 | Carson, J.
Plaintiff: The United States

Defendants: Francisco Bautista, Aniceto de Guzman, Tomas Puzon
Topic: Conspiracy to commit treason
Doctrine:
 The acceptance or possession of an appointment as an officer of the military forces of a

conspiracy, without the execution of any external act, does not constitute sufficient proof of
the guilt of the defendant.
 The two-witness rule in the prosecution of the crime of conspiracy does not apply to that of
conspiracy to commit treason.
FACTS:
 Appellants were convicted by the CFI of Manila of the crime of conspiracy to overthrow, put
down, and destroy by force the Government of the US in the Philippines and the Government of
the Philippine Islands, where they were sentenced to imprisonment, hard labor, and fine.
 In 1903, a junta was formed in Hongkong, and some Filipinos there entered into a conspiracy for
the purpose of overthrowing the Government of the US in the Philippines by forms of arms, and
establishing a government to be known as the Republica Universal Democratica Filipina.
 Artemio Ricarte, the chief of the military forces organized in the Philippines for the conspiracy,
went back to the Philippines on December 1903 where he conducted several meetings in Manila.
In these meetings, the conspiracy hatched in Hongkong was perfected. Plans were made for the
enlistment of a revolutionary army, and bonds were issued to raise funds for the advocacy.
Commissions were also sent out to the officers of the revolutionary army.
 Some of these meetings were attended by petitioner Francisco Bautista, a friend of Ricarte. In one
of these meetings, he answered to one of Ricarte’s question that necessary preparations had been
made and that he had held the people in readiness.
 Petitioner Tomas Puzon, on the other hand, was an intimate friend of J.R. Muñoz, a prime leader
of the movement. In the intimate confidence of Ricarte, Muñoz offered to Puzon a commission as
brigadier-general of the signal corps established in the Philippines. Puzon undertook his part in
organizing the troops, and told Muñoz, in one of the meetings, that he had duly organized his
forces in accordance to the terms of his commission.
 The forces then organized took the field and offered armed resistance to the constituted
authorities in the Philippines. The effort, however, failed.
 Aniceto de Guzman, on the other hand, was found guilty of being part of the conspiracy for his
acceptance of a number of bonds from one of the conspirators. It does not, however, appear that
de Guzman knew of the existence of the conspiracy. When he opened the parcel containing the
bonds, he immediately burnt the contents upon finding out what it was.
ISSUES:
1. W/N the acceptance of a commission for an army constituted to overthrow the government makes
one part of the conspiracy to commit treason – YES, if the accused voluntarily accepted the
commission.
2. W/N the restrictive two-witness rule applied in treason also applies in conspiracy to commit
treason – NO.
HELD:
1. In a confession Puzon made after he was apprehended, he admitted accepting the commission
offered by Muñoz “on account of friendship” and “not to vex a friend.” The Court held that while
mere acceptance of a commission as an officer of the military forces to overthrow the
government, with no other external acts executed does not constitute treason, it constitutes the
crime of conspiracy to commit treason, provided that the acceptance was made voluntarily, and
that the fact of the conspiracy has been proven. Such is the matter in the case at bar.
2. The two-witness rule applied in the crime of treason does not apply to the crime of conspiracy to
commit treason. The latter is a separate and distinct crime from that of treason.
DISPOSITIVE:
CFI decision as it applies to Buatista and Puzon is affirmed; modified as it applies to de Guzman. The
Court acquitted de Guzman, and ordered his immediate release.

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US v. FRANCISCO BAUTISTA, ET.AL.

G.R. NO. 2189 | November 03, 1906 | Carson, J.

Plaintiff: The United States

 The acceptance or possession of an appointment as an officer of the military forces of a

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