04/02/2025, 22:11 People vs.
Perez
Title
People vs. Perez
Case Decision Date
G.R. No. 21049 22 Dec 1923
Isaac Perez, a municipal secretary, convicted for seditious statements against
Governor-General Wood, inciting rebellion and disturbing public peace under Act No.
292.
Jur.ph - Case Digest (G.R. No. 21049)
Direct Answer Model - Comprehensive
Facts:
The case of The People of the Philippine Islands vs. Isaac Perez (G.R. No. 21049) arose from
an incident that occurred on April 1, 1922, in the municipality of Pilar, Sorsogon. Isaac
Perez, who served as the municipal secretary, engaged in a heated discussion with
Fortunato Lodovice, a local citizen, regarding the administration of Governor-General
Leonard Wood. During this discussion, Perez made inflammatory remarks, stating that "the
Filipinos, like myself, must use bolos for cutting off Wood's head for having recommended
a bad thing for the Filipinos, for he has killed our independence." This statement was made
in a public place and was overheard by several individuals. Consequently, Perez was
charged in the Court of First Instance of Sorsogon with violating Article 256 of the Penal
Code, which pertains to contempt against ministers of the Crown or other persons in
authority. The trial court found him guilty, leading to an appeal by Perez to a higher court.
The primary contention in the appeal was whether the words spoken by Perez constituted a
crime and, if so, which specific law was violated.
Issue:
1. What crime, if any, did Isaac Perez commit with his statements against Governor-
General Leonard Wood?
2. Is Article 256 of the Penal Code still in force, and does it apply to the actions of Perez?
3. Should Perez be convicted under Article 256 of the Penal Code or under the Treason
and Sedition Law (Act No. 292)?
Ruling:
The court ruled that Isaac Perez's statements constituted a violation of Section 8 of Act No.
292, the Treason and Sedition Law, rather than Article 256 of the Penal Code. The court
affirmed the trial court's judgment, modifying the conviction to reflect the appropriate law
under which Perez was found guilty. He was sentenced to two months and one day of
imprisonment and ordered to pay costs.
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04/02/2025, 22:11 People vs. Perez
Ratio:
The court's reasoning centered on the nature of Perez's statements, which were deemed
seditious rather than merely contemptuous. The court acknowledged that while criticism
of government officials is permissible under the freedom of speech, Perez's remarks
crossed the line into incitement of violence and disturbance of public peace. The court
referenced previous cases that established the distinction between permissible criticism
and seditious speech. It concluded that Perez's words were not just an insult but had the
potential to incite rebellion and disturb the peace, thus falling under the purview of the
Treason and Sedition Law. The court emphasized that the law must be enforced to
maintain public order and the authority of the government, particularly when the remarks
could lead to disaffection among the populace. The court's decision underscored the
importance of balancing freedom of expression with the need to protect the state and its
institutions from seditious acts.
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