CASE DIGEST ON U.S. V. BAUTISTA [6 Phil. 581 (1906)]

Nature: Appeal from the judgment of the Manila CFIFacts: In 1903 a junta was organized and a conspiracy entered into by a number of Filipinos in Hongkong, for the purpose of overthrowing the government of the United States in the Philippine Islands by force of arms and establishing a new government.Francisco Bautista (1), a close friend of the chief of military forces (of the conspirators) took part of several meetings. Tomas Puzon (2) held several conferences whereat plans are made for the coming insurrection; he was appointed Brigadier-General of the Signal Corps of the revolutionary forces. Aniceto de Guzman (3) accepted some bonds from one of the conspirators.The lower court convicted the three men of conspiracy. Bautista was sentenced to 4 years imprisonment and a P3,000 fine; Puzon and De Guzman to 3 years imprisonment and P1,000.Issue: WON the accused are guilty of conspiracy.Held: Judgment for Bautista and Puzon CONFIRMED. Judgment for de Guzman REVERSED. Yes, Bautista and Puzon are guilty of conspiracy. Bautista was fully aware of the purposes of the meetings he participated in, and even gave an assurance to the chief of military forces that he is making the necessary preparations. Puzon voluntarily accepted his appointment and in doing so assumed all the obligations implied by such acceptance. This may be considered as an evidence of the criminal connection of the accused with the conspiracy.However, de Guzman is not guilty of conspiracy. He might have been helping the conspirators by accepting bonds in the bundles, but he has not been aware of the contents nor does he was, in any occasion, assumed any obligation with respect to those bonds.Note: see RPC Art. 136: Crimes against public order: conspiracy and proposal to commit coup d’ etat, rebellion or insurrection.