US v. Bautista (1906)

United States v.
Bautista
G.R. No. 2189 – Nov 3, 1906
J. Carson
Topic: Proposal and Conspiracy
Art 8 Par 2, RPC — A conspiracy exists when two or more persons come to an agreement concerning the
commission of a felony and decide to commit it.
Plantiff and appellee: United States

Defendants and appellants: Francisco Bautista, et al.
FACTS:
• Appellants were convicted in the Court of First Instance Manila of the crime of conspiracy to
overthrow the US government in the Philippines as defined and penalized in Sec 4 of Act No. 292 of
the Philippine Commission.
• Appellants were sentenced:
• Francisco Bautista — 4 years imprisonment, with hard labor, $3,000 fine.
• Aniceto De Guzman and Tomas Puzon — 3 years imprisonment, with hard labor, $2,000
fine.
• In 1903 a junta was organized and a conspiracy entered into by a number of Filipinos to overthrow
the US gov’t in the Philippines and establish República Universal Democrática Filipina
• Prim Ruiz — titular head of conspiracy
• Artemio Ricarte — chief of military forces
• came to Manila from Hongkong in Dec 1903; held a number of meetings in Manila to
plan the conspiracy
• The junta failed because they did not combat successfully and because the people failed to
rise en masse to their propaganda
• Evidence showed that Francisco Bautista was a friend of Ricarte; that Ricarte notified him of his
coming to Manila; that Bautista forwarded to him 200 pesos to aid in his journey; that Bautista took
part in the meetings headed by Ricarte.
• Tomas Puzon was found to have united with conspirators through Jose Muños (prime leader of the
movement)
• Puzon held several conferences with Muñoz where plans for the insurrection were made.
• Muñoz offered Puzon a commission as brigadier general of the signal corps of the
revolutionary forces. Puzon voluntarily accepted the commission and united himself with
the conspirators; later on informed Muñoz that he had duly organized in accordance
with the terms of his commission.
ISSUES + HELD:
1. W/N by accepting the appointment, Tomas Puzon was guilty of conspiracy — YES.
• At the trial, Puzon claimed that he did not unite with the conspirators and that he accepted the
commission just to avoid vexing his friend Muñoz. This was not accepted by the Court in light of
his signed written statement.
• The Court ruled that the accused actually and voluntarily accepted the appointment and
assumed obligations of the appointment which was construed as evidence of his criminal
relations with the conspirators.
• It was contended that the acceptance or possession of an appointment as an officer of the
military forces of the conspiracy should not be considered as evidence against him in light of
the following cases: US v. De los Reyes; US v. Nuñez et al.; US v. de la Serna; and US v.
Manalo. The Court said that the case at bar should be distinguished from these cases.
• US v De los Reyes — mere acceptance of a commission with nothing else done was
not an overt act of treason
• US v. Nuñez — no evidence to show that the crime of brigandage was committed
• US v. de la Serna — evidence did not show that accused confessed that he was part
of the pulajanes
• US v. Manalo — mere possession of appointment is not sufficient to convict
2. W/N By the acceptance of a number of bonds, Aniceto de Guzman is guilty of conspiracy — NO.
• Evidence does not sustain his conviction.
• His guilt rests upon his acceptance of bonds from one of the conspirators but it did to
affirmatively appear that he knew anything of the existence of the conspiracy. He never
assumed obligations with respect to the bonds. He even destroyed the contents of the bonds.
RULING: Aniceto de Guzman should be ACQUITTED of the crime he is charged and set at liberty
fortwith, and that the judgement and sentence of the trial court, insofar as it applies to Francisco Bautista
and Tomas Puzon should be, and is hereby, AFFIRMED.
DISSENT:

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United States v.

Topic: Proposal and Conspiracy

Plantiff and appellee: United States

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