United States v Exaltacion

No. 1481, 17 Feb 1904, Torres, J.

 
Rhoda Reventar Law 109 – Crim Group B3
 
FACTS
Appeal from judgment of the Court of First Instance of Bulacan
• Liberato Exaltacion and Buenaventura Tanchinco were charged with the crime of rebellion. That they
swore allegiance to the Katipunan Society, for the purpose of which was to overthrow the Government
by force of arms.
• Don Pablo Tecson, provincial governor of Bulacan, testified under oath that the defendants were
arrested in the month of March, 1903. The police captured a number of documents days before the
arrest in the encampment of on Contreras (general of the bandits). Among the documents were papers
signed by the defendants, which they recognized. Documents were in Tagalog and contain an oath taken
in the name of God, and a covenant on the part of the subscribers to carry out the superior orders of the
Katipunan, an never disobey them until death in the defense of the mother country.

ISSUES/HELD

WoN the Exaltacion and Tanchinco are guilty of rebellion? NO

RATIONALE

Both defendants said that they signed the document under compulsion and force when they were held captives
by thieves.

Defendant Tanchanco
• On his way to work, he was captured by 3 armed men
• Asked if he was agent or friend of President Testa
• Replied in the negative then compelled him in view of his denial to sign a document
• Lazaro Yusay testified for Tanchinco
• Reported incident to President Testa
Defendant Exaltacion
• Captured near Meycauayan by 5 persons, dressed as policemen, armed with guns or revolvers
• Bound and took him to the forest
• Compelled him by threat of death to sign the documents, then released upon promise to return
• Antero Villano and Tomas Rivera saw him on the road in the hand of the thieves
• Presented himself to President Testa after the incident

The facts established by the evidence, that the defendants were kidnapped by brigands who belonged to the
Contreras band, and that they signed the said documents under compulsion and while in captivity, relieve
them from all criminal liability from the crime of rebellion of which they are charged. The conduct of the
defendants in presenting themselves first to the local president of Meycauayan and subsequently to Leiut.
Bonifacio Morales, of the Bulacan Government Volunteers, as soon as they were released by the bandits is
corroborative of their testimony, and is the best demonstration of their innocence.