Case # 13 US vs RAVIDAS GR No.

1503

FACTS

The individuals named as defendants in this case are Alejo Ravidad and Narciso Melliza. They face charges
related to the crime of insurrection. Among the twenty-five defendants initially involved, five were acquitted in
the lower court, while the remaining twenty were found guilty and received prison sentences. Subsequently, all
twenty defendants were granted the right to appeal, but during the appeal process, eight chose to withdraw
from the appeal, and another eight managed to escape from the provincial jail.

The escape of these defendants during the pendency of their appeal was deemed as a voluntary withdrawal,
resulting in the finality of the court's judgment from the initial trial. The complaint lodged against the
defendants pertains to the crime of insurrection, as defined by Act No. 292 of the Civil Commission. However,
the evidence presented did not establish that the defendants actively promoted, encouraged, or aided
insurrection, nor did it show their direct participation in such activities.

Specifically, Alejo Ravidad was aware of insurgents in Manila, but his silence and omission to report this
information were deemed insufficient to constitute the crime of insurrection. As for Narciso Melliza, who sold
rice to individuals later revealed to be insurgents, there was no evidence demonstrating that he knowingly sold
the rice with the intention of aiding the insurrection. In light of these considerations, the court ruled that the
charges against Alejo Ravidad and Narciso Melliza lacked sufficient evidence to support their culpability for the
crime of insurrection.

ISSUE

Can Alejo Ravidad and Narciso Melliza be held liable for the crime of insurrection?

RULING

No. The court decided to acquit the defendants, Alejo Ravidad and Narciso Melliza, based on a lack of evidence
showing their active involvement in promoting, encouraging, or aiding insurrection. The Government's counsel
requested their acquittal, highlighting the absence of proof for such involvement. The only presented fact was
that Ravidad knew about insurgents but didn't report it or take action. However, the court ruled that his silence
wasn't a punishable act under Act No. 292, and thus, it didn't constitute the crime of insurrection. The court
agreed with the counsel's argument, concluding that the facts presented were insufficient to hold Ravidad
liable for insurrection.

Similar considerations were applied to Melliza, where no evidence indicated his active involvement in
promoting or aiding insurrection. The only established fact was his sale of rice to individuals who later were
revealed as insurgents, but this alone did not render him criminally liable. There was no proof that Melliza
knowingly sold the rice with the intention of aiding the insurrection.

Based on these considerations, the court reversed the judgment of the lower court and acquitted Ravidad and
Melliza. The appeal of the other defendants who withdrew or escaped was dismissed, and the judgment of the
lower court was affirmed and made final for them. The court ordered the immediate release of Ravidad, who
was the only one confined in prison, and noted that Melliza was already out on bail. The costs of the case
were to be shouldered by the government.

PRINCIPLE

The principle in the court's ruling, concerning the crime of insurrection, is that mere knowledge of or
association with individuals involved in insurgent activities, without active participation in promoting,
encouraging, or aiding insurrection, is not sufficient to establish criminal liability. The court emphasized the
necessity of concrete evidence showing a defendant's direct involvement in acts that contribute to or support
insurrection.