The insurgency problem of the country dates hundred years ago. When Cebuano patriots rose against the Spaniards in Cebu in 1898 and when the Americans became the new invaders by the end of 1898, they were faced by resistance.
Most of the Cebuano patriots surrendered and were caught by the Americans in 1901. In Cebu, a group of patriots known as the "Pulahanes", were the reason why the United States appointed a military governor, to curb the resistance against their rule. Adna Chaffee, the military governor was the sole authority under the Philippine Commission, appointed by the American president and approved by the American Senate.
The group (Pulahanes) continued to give problems to the Americans, thus it used Filipino leaders as intermediary for its surrender. Don Sergio Suico Osmeña earned the support of the Americans by facilitating the surrender of the leaders of the Pulahanes.
In Barili, Cebu, Eusebio dela Serna and Enrigue Camonas were convicted by the Court of First Instance of Cebu of the crime of sedition. The allegations against them were that they, armed with deadly weapons, destroyed public properties in Barili. Allegedly, dela Serna put fear to the inhabitants of the municipality. However, no proof was ever presented by the prosecution of the crime of sedition. The crimes alleged to have happened on the months of April and May of 1903. The courts at that time were presided mostly by American judges.
The Barilinos, assisted by lawyer Rafael Palma, went to the Supreme Court and appealed their conviction. Justice Mapa who wrote the decision of the Supreme Court en banc (with the whole court deciding) said that the conviction based simply on a Philippine Constabulary officer testimony that accused Eusebio dela Serna said to him that he was appointed as colonel of the insurgents was not enough proof.
The Supreme Court then said that the supposed appointment as a colonel or sergeant (accused Camonas) of a band (the Americans called the Cebuano Patriots as a "band", the same as a group of robbers and thieves, there are Americans who called them "Ladrones"), when it is not specified from what band is not conclusive or does not mean that they have committed the crime of sedition.
The Supreme Court on April 25, 1905 reversed the conviction of the dela Serna and Camonas and ordered that they be released.