People v. Feleo
REITERATIONFacts
The Antecedents: On the evening of December 7, 1930, a public meeting was held by communists in the barrio of Tambo, municipality of San Leonardo, Province of Nueva Ecija. The appellant, Juan Feleo, a communist leader, delivered speeches before an audience of about one hundred persons, including members of the Philippine Constabulary. Constabulary witnesses testified that Feleo's speech contained words inciting listeners to imitate French soldiers who shot their chiefs instead of enemies, urging them to use arms against the American government, and hoping for the desertion of Constabulary men and scouts to side with the "reds" to defend the Philippines. Feleo also allegedly criticized the salaries of American officials compared to Constabulary privates and expressed hope that with unity and a "rebellious heart," the oppressive American government would leave, and the communists would own haciendas and the railroad company. Procedural History: The Court of First Instance of Nueva Ecija found the appellant, Juan Feleo, guilty of sedition or inciting seditious acts, in violation of section 8 of Act No. 292 of the Philippine Commission, sentencing him to one year of imprisonment and costs. The Petition: The appellant appealed the judgment, raising two legal questions: (1) whether the law under which he was convicted contravened the freedom of speech and press guaranteed by the Jones Law, and (2) whether the words used were in fact seditious.
Issue(s)
Whether the provision of law under which the appellant was convicted contravenes the fundamental principle of freedom of speech or of the press guaranteed by the Jones Law. Whether the words used by the appellant were of a seditious character.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, finding the appellant guilty of sedition. The Court held that the constitutional guaranty of freedom of speech and press does not grant an unqualified right to speak or publish without responsibility, and that the state may punish abuses of this freedom that tend to disturb the public peace. The words spoken by the appellant were deemed seditious as they incited listeners to take up arms against constituted authorities and to rise against the established government, and encouraged soldiers to disobey superior officers and revolt.
Ratio Decidendi
On the issue of freedom of speech and press versus sedition: The Court held that the constitutional guaranty of freedom of speech and of the press does not grant an unqualified right to speak or publish without responsibility. The state, in the exercise of its police power, may punish those who abuse this freedom and whose language tends to disturb the public peace. This principle is well-established doctrine, as seen in cases like Gitlow vs. New York. Therefore, the provision of law under which the appellant was convicted does not contravene the fundamental principle of freedom of speech or of the press. On whether the words used were seditious: The Court found that the words spoken by the appellant were indeed of a seditious character. The appellant incited the hearers to imitate French soldiers who, instead of pointing arms at their enemies, directed their weapons towards their own chiefs. He explicitly stated that the provincial commander of the Constabulary would fall and that the communists would become owners of haciendas and the railroad company. Furthermore, he expressed hope that the Constabulary force and scouts would desert to side with the "reds." Such language is properly considered seditious because it tends to incite the people to take up arms against the constituted authorities and to rise against the established government. The reference to alleged injustices and the urging of soldiers to cherish a "rebellious heart" clearly indicated a tendency to incite disobedience to superior officers and revolt, as well as acts of hate and vengeance upon other persons. The testimony of the Constabulary witnesses, who had no apparent motive to misquote and made their reports in the course of duty, was found to be truthful and accurate regarding the substance of the words spoken.
Main Doctrine
The constitutional guaranty of freedom of speech and press does not grant an unqualified right to speak or publish without responsibility; the state may punish those who abuse this freedom and whose language tends to disturb the public peace. Words inciting people to take up arms against constituted authorities or to rise against the established government are considered seditious.