US vs Francisco Bautista et al 6 Phil 581

Crime: Conspiracy to treason

Facts:
Francisco Bautista, Aniceto de Guzman, and Tomas Puzon were convicted
in the CFI of Manila the crime of conspiracy to overthrow, put down,
and destroy by force the US Government in the PH Islands and the
Government of the Philippine Islands as defined and penalized in Sec.
4, Act No. 292 of the Philippine Commission.
In the year 1903, a junta was organized, and a conspiracy was entered
by a number of Filipinos in Hongkong for the purpose of overthrowing
the US and Philippine Government, led by its titular head, Prim Ruiz
and chief of the military forces, Artemio Ricarte. The conspiracy was
planned to establish in the Philippines. Ricarte came to the
Philippines and held a number of meetings whereat perfected
conspiracy, in which new members were taken into the conspiracy and
plans made for the enlistment of an army of revolution and the raising
of money vias national and private loans to carry the campaign.
They raised troops and dealt with Philippine authorities but were soon
failed to combat successfully and the failure of the people to rise en
masse in response to their propaganda. Francisco Bautista founded to
be an intimate friend of Ricarte and aided Ricarte upon his comeback
to the Philippines, forwarding him secretly 200 pesos and attended
meetings with him. He also assured Ricarte about the preparations for
the plan.
Tomas Puzon on the other hand, appeared to be united with the
conspirators through the agency of Jose Munoz who was proven to be a
prime leader of the movement. Puzon held several conferences with
Munoz for the plans of coming insurrection, in which Munoz offered
Puzon the position of Brigadier-General of the signal corps. At the
trial, Puzon declared he had never united himself with the
conspirators despite his acceptance of the appointment, stating he had
no intention of taking any further action because he did not want to
vex Munoz. He said that he did not know Ricarte was in Manila
organizing the conspiracy at that time.

Issue:

1. Whether or not Aniceto de Guzman is guilty of conspiracy to

treason.
2. Whether or not Francisco Bautista and Tomas Puzon is guilty of
conspiracy to treason.
Ruling:
1. NO. The evidence does not sustain the conviction of Aniceto de
Guzman. Although he received a number of bonds intended to fund
the movement and plans for conspiracy, it does not affirmatively
appear that he knew anything of the existence of the conspiracy.
He never assumed any obligation and thus destroyed the bonds upon
opening them. He had no dealings with the conspirators in
relation to the conspiracy.

2. YES. As per Puzon, not only a mere acceptance is what makes him
guilty of conspiracy to treason, but a genuine conspiracy is
shown to have existed as in this case and it is proven that he
voluntarily accepted an appointment as an officer to the
conspiracy, as this fact may properly be taken into consideration
as evidence of his relations with the conspirators.