Criminal Law 2 – Assignment 02

Grace Dela Rama, JD1-A

People vs. Umali

G.R. No. L-5803, November 29, 1954

Facts:
Umali, Pasumbal and Capino were found guilty by the CFI of Quezon
province of the complex crime of rebellion with multiple murder, frustrated
murder, arson and robbery. This complex crime was the result of the raid planned
by the armed men of the town which caused the burning down and complete
destruction of houses, including that of Mayor Punzalan. Before being dispersed
and chased out of town by the Philippine Army soldiers, some of the raiders also
participated in looting and in robbing one house and two Chinese stores.
Records showed that Mayor Punzalan and Congressman Umali were close
friends and members of the same political party. This friendly relation, however,
did not prevail. In the elections of 1951, Punzalan ran for re-election. To oppose
him, Umali picked Pasumbal his trusted leader. Punzalan won. Naturally, Umali
and Pasumbal were disappointed. It appears that Umali gave Pasumbal the order to
get in touch with the Huks the night before the elections in order to assassinate
Punzalan. The Huk troops, numbering around 50 and equipped with garands and
carbines, then carried out the raid. Punzalan's home was assaulted by a portion of
the group using hand grenades, automatic firearms, and even gasoline-filled
bottles. It was evident that the purpose of the attack on Punzalan’s house was to
kill him. Fortunately, Punzalan left early morning to go to Lucena, the capital.

Issues:
Whether the trial court is correct in finding the accused guilty of
the complex crime of rebellion with multiple murder, frustrated murder,
arson and robbery.

Ruling:
No, the court ruled that the principal and main crime committed was not
rebellion but rather that of sedition. The purpose of the raid and the act of the
raiders in rising publicly and takin up arms was not exactly against the
Government and for the purpose of doing the things defined in Article 134 of the
RPC under rebellion. The raiders did not even attack the President rather the object
was to attain by means of force, intimidation, etc. one object, to wit, to inflict an
act of hate or revenge upon the person or property of a public official, Mayor
Punzalan. Under Article 139 of the same code, this was sufficient to constitute
sedition.