Primary Holding

The Supreme Court affirmed the doctrine in People v. Hernandez (1956), holding that rebellion absorbs all crimes committed in furtherance of rebellion and cannot be charged as a complex crime with murder, arson, or robbery. The Court modified the penalties imposed, aligning them with those prescribed for rebellion under Articles 134 and 135 of the Revised Penal Code.

Background

The accused were leaders or members of the Communist Party of the Philippines (CPP) and the Hukbong Mapagpalaya ng Bayan (HMB), formerly known as Hukbalahap (Huks). The government alleged that they conspired to overthrow the government through armed rebellion, organizing violent raids, ambushes, and assassinations. The trial court sentenced several defendants to death or life imprisonment, leading to an appeal before the Supreme Court.

Facts

• 1. The Communist Party of the Philippines (CPP) and its armed wing, the Hukbong Mapagpalaya ng Bayan (HMB), allegedly planned and executed attacks on government forces to overthrow the government.
• 2. The Politburo of the CPP gave direct orders for raids, assassinations, and attacks on military and police forces.
• 3. Evidence of Communist documents (party charters, directives, and reports) indicated that the defendants held leadership roles and actively conspired in the rebellion.
• 4. Violent incidents, such as the murder of Lt. Mamerto Lorenzo and the attack on Camp Macabulos in 1950, were presented as part of the rebellion.

Arguments of the Petitioners

• 1. The defendants were part of a nationwide Communist conspiracy that used violence to overthrow the government.
• 2. The acts of murder, arson, and robbery should be considered distinct from rebellion, warranting heavier penalties.
• 3. The trial court properly convicted the defendants based on voluminous evidence, including seized Communist Party documents.

Arguments of the Respondents

• 1. The charge was defective because rebellion cannot be complexed with other crimes under People v. Hernandez (1956).
• 2. The trial court violated due process by allowing reconstituted evidence after the original evidence was burned.
• 3. Their constitutional rights were violated by illegal searches and seizures.

Issues

• 1. Can rebellion be charged as a complex crime with murder, arson, and robbery?
• 2. Did the trial court err in admitting reconstituted evidence after the original documents were destroyed?
• 3. Were the constitutional rights of the defendants violated?

Ruling

• 1. Rebellion Cannot Be Complexed with Other Crimes - The Supreme Court reaffirmed the People v. Hernandez doctrine, ruling that rebellion absorbs all crimes committed in furtherance of it. The Court emphasized that murder, arson, robbery, and other common crimes cannot be separately charged alongside rebellion, as they are considered essential means of carrying out the rebellion itself. Because of this, the accused should only be convicted of simple rebellion under Articles 134 and 135 of the Revised Penal Code.
• 2. Reconstituted Evidence Was Properly Admitted - The Court ruled that the trial court correctly admitted reconstituted evidence following Act No. 3110, which governs the restoration of lost or destroyed judicial records. The original documents were lost due to a fire, but secondary evidence—including photostatic copies, typewritten transcripts, and witness testimonies—was deemed sufficient for use in court. The Court rejected the defendants' claim that their right to due process was violated due to this reconstitution.
• 3. No Violation of Constitutional Rights - The Supreme Court found that the searches and seizures conducted against the accused were lawful, as valid search warrants had been obtained before the raids. Additionally, the accused were afforded due process and had ample time and opportunity to prepare their defense. Since most of the accused either testified or presented evidence, and they were represented by competent legal counsel, the Court ruled that there was no violation of their constitutional rights.

Doctrines

• 1. People v. Hernandez Doctrine (1956): Rebellion absorbs all crimes committed in furtherance of the rebellion.
• 2. Principle of Judicial Restraint: Courts must enforce laws as written, not as judges would prefer.

Key Excerpts

• 1. “The crime of rebellion cannot be complexed with murder, arson, or robbery; all these crimes are absorbed in the single crime of rebellion.”
• 2. “The policy of leniency for rebellion remains unchanged since 1932; any modification must be done by Congress, not the Judiciary.”

Precedents Cited

• 1. People v. Hernandez (1956) – Established that rebellion absorbs common crimes.
• 2. People v. Geronimo (1956) – Further clarified that acts of violence are part of rebellion, not separate crimes.
• 3. People v. Aquino (1960) – Stated that killing in furtherance of rebellion is not separate murder.

Statutory and Constitutional Provisions

• 1. Revised Penal Code - Article 134 – Rebellion or Insurrection - Defines rebellion as a public uprising and taking up arms against the government for the purpose of removing Philippine territory or any government authority from the control of the state.
• 2. Revised Penal Code - Article 135 – Penalty for Rebellion or Insurrection - Imposes the penalty of prisión mayor (six to twelve years) and a fine for those who lead, promote, or participate in rebellion. If the rebellion is committed by someone in public office, additional penalties apply.
• 3. Revised Penal Code - Article 136 – Conspiracy and Proposal to Commit Rebellion - States that conspiracy to commit rebellion is punishable with prisión correccional in its maximum period (four years, two months to six years) and a fine, even if the rebellion itself is not carried out.
• 4. Rules of Court - Rule 110, Section 14 – Venue for Criminal Actions - Provides that criminal cases must be filed in the jurisdiction where the offense was committed or where any essential ingredient of the crime took place. The Court held that since the accused allegedly planned and directed rebellion from Manila, the case was properly heard in the Manila court.
• 5. Rules of Court - Rule 117, Section 12 – Prohibition on Duplicitous Charges - Prohibits an information (criminal charge) from including more than one offense, unless the law specifically allows for complex crimes. The Supreme Court ruled that charging rebellion with other common crimes violated this rule, as rebellion is a single offense encompassing all acts committed in furtherance of it.