People v. Evangelista
REITERATIONFacts
The Antecedents: Crisanto Evangelista, Jacinto G. Manahan, and Dominador J. Ambrosio were charged with violating section 8 of Act No. 292 of the Philippine Legislature. The information alleged that they were founders, organizers, promoters, directors, and leading members of the Partido Komunista sa Pilipinas (Communist Party of the Philippines). The Party's principal object was to incite a revolt of the proletariat or laboring class, advocating for revolt under the leadership of laborers to establish an independent government, overthrow American imperialism and capitalism, establish a Soviet government under laborers, and embrace communism. They were accused of uttering seditious words and speeches at public meetings, advocating for revolt, class struggle, and the overthrow of the government, similar to the Russian laborers. They also read and distributed the Party's constitution and by-laws, soliciting memberships. The contents and spirit of these documents and speeches were deemed scurrilous libels against the governments of the United States and the Philippine Islands, inciting rebellious conspiracies and tending to disturb the peace and safety of the government. Procedural History: The accused were charged in the Court of First Instance of Manila. The court found them guilty. The Petition: The accused appealed the decision of the Court of First Instance.
Issue(s)
Whether the expressions attributed to the appellants were accurate reproductions of their speeches. Whether the appellants violated section 8 of Act No. 292, as amended by Act No. 1692, by advocating for revolution and overthrowing the government. Whether the acts charged constitute a crime under the Revised Penal Code.
Ruling
The appealed judgment is affirmed, with one-third of the costs against each of the appellants.
Ratio Decidendi
On the accuracy of speech reproductions: The contention that the agents making extracts of the speeches were incapable of doing so is untenable. Reporting the substance of speeches on matters like revolution and overthrowing the government does not require special skill. The orators spoke in a manner understandable to the common people, and if the extracts were inaccurate, the appellants could have presented contradictory evidence, which they did not. The testimony of some accused even confirmed the extracts. On the violation of section 8 of Act No. 292: The appellants circulated pamphlets containing the constitution and by-laws of the Communist Party of the Philippines and delivered speeches advocating its ideas, which were deemed highly seditious and revolutionary. The defense that no disturbance or disorder took place is untenable, as established in People vs. Perez. It is sufficient that the act incites uprising or produces a feeling incompatible with the permanency of the government. The acts were not mere expositions of doctrines in abstracto, as they tended to incite rebellion. On whether the acts constitute a crime under the Revised Penal Code: The contention that the acts do not constitute a crime under the Revised Penal Code is also untenable. Article 142 punishes inciting sedition by speeches, manifestos, etc. Sedition, under Article 139, includes public and tumultuous uprising to attain certain purposes by force, such as preventing the government from freely exercising its functions. The expressions and utterances by the appellants incited people to uprise and overthrow the Government by force and arms, thus falling under the sanction of the Revised Penal Code. The penalty under Article 142 is higher than that under section 8 of Act No. 292, as amended.
Main Doctrine
The utterance of seditious words or speeches, the circulation of seditious libels, and the advocacy of revolutionary means to overthrow the government, even without actual disturbance or breach of peace, constitute a violation of laws penalizing sedition and inciting rebellion.