The document summarizes several cases related to treason charges during the Japanese occupation of the Philippines. In the Laurel v. Misa case, the court held that allegiance to the legitimate government is not suspended during occupation and those accused can still be charged under the Revised Penal Code. In People v. Manayao, the accused were found guilty as the paramilitary group Makapili they joined did not transfer citizenship to Japan. In People v. Perez the accused was acquitted of treason but convicted of rape. In People v. Prieto the accused was convicted on counts admitted to but acquitted where evidence did not meet the two-witness standard for treason charges. The two-witness rule for treason charges was also discussed
The document summarizes several cases related to treason charges during the Japanese occupation of the Philippines. In the Laurel v. Misa case, the court held that allegiance to the legitimate government is not suspended during occupation and those accused can still be charged under the Revised Penal Code. In People v. Manayao, the accused were found guilty as the paramilitary group Makapili they joined did not transfer citizenship to Japan. In People v. Perez the accused was acquitted of treason but convicted of rape. In People v. Prieto the accused was convicted on counts admitted to but acquitted where evidence did not meet the two-witness standard for treason charges. The two-witness rule for treason charges was also discussed
The document summarizes several cases related to treason charges during the Japanese occupation of the Philippines. In the Laurel v. Misa case, the court held that allegiance to the legitimate government is not suspended during occupation and those accused can still be charged under the Revised Penal Code. In People v. Manayao, the accused were found guilty as the paramilitary group Makapili they joined did not transfer citizenship to Japan. In People v. Perez the accused was acquitted of treason but convicted of rape. In People v. Prieto the accused was convicted on counts admitted to but acquitted where evidence did not meet the two-witness standard for treason charges. The two-witness rule for treason charges was also discussed
The document summarizes several cases related to treason charges during the Japanese occupation of the Philippines. In the Laurel v. Misa case, the court held that allegiance to the legitimate government is not suspended during occupation and those accused can still be charged under the Revised Penal Code. In People v. Manayao, the accused were found guilty as the paramilitary group Makapili they joined did not transfer citizenship to Japan. In People v. Perez the accused was acquitted of treason but convicted of rape. In People v. Prieto the accused was convicted on counts admitted to but acquitted where evidence did not meet the two-witness standard for treason charges. The two-witness rule for treason charges was also discussed
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LAUREL v.
MISA
77 PHIL 856FACTS:
Anastacio Laurel filed a petition for habeas corpus contending that he cannot be prosecuted for the crime of treason defined and penalized by the Article 114 of the Revised Penal Code on the grounds that the sovereignty of the legitimate government and the allegiance of Filipino citizens was then suspended, and that there was a change of sovereignty over the Philippines upon the proclamation of the Philippine Republic.
ISSUE:
1. Is the absolute allegiance of the citizens suspended during Japanese occupation?
2. Is the petitioner subject to Article 114 of the Revised Penal Code?
HELD:
The absolute and permanent allegiance of the inhabitants of a territory occupied by the enemy of their legitimate government on the sovereign is not abrogated or severed by the enemy occupation because the sovereignty of the government or sovereign de jure is not transferred to the occupier. There is no such thing as suspended allegiance.
The petitioner is subject to the Revised Penal Code for the change of form of government does not affect the prosecution of those charged with the crime of treason because it is an offense to the same government and same sovereign people. 78 PHIL 721
PEOPLE VS. MANAYAO
FACTS: The three accused were charged with treason complexed with multiple murder in the People’s Court. They participated in the massacre of several citizens who were suspected to have been helping the guerillas. The accused claimed that they cannot be tried since the Court has no jurisdiction. Furthermore, they claimed that they had renounced their Filipino citizenship after joining the Japanese paramilitary Makapili, and then swearing allegiance to Japan.
HELD/RATIO: The accused were found guilty. The Makapili is not a part of the Japanese army. It was an organization of Filipino traitors. Moreover, there is no evidence that the accused swore to an oath of allegiance when they entered the said organization. Furthermore, it is the lone prerogative of the State to allow or deny one’s change of citizenship. 83 PHIL 314 People vs. Perez
FACTS: Accused Perez was charged with treason and rape. The accused kidnapped several women in order to present them to a Japanese Commander to satisfy the latter’s carnal pleasure against the will of the women. In some instances, the accused himself raped several women.
HELD/RATIO: The accused was acquitted in relation to the crime of treason; but, he was found guilty in relation to the crime of rape. The acts of the accused in relation with the Japanese didn’t directly and materially tend to improve the war efforts or to weaken the power of the United States. Moreover, intent of disloyalty – which is essential in the crime of treason – is lacking. Nevertheless, the accused can be held liable for the several counts of rape he committed. 80 PHIL 138 People vs. Prieto
FACTS: Accused Prieto was charged with treason. During the Japanese occupation, the accused joined the paramilitary force of the Japanese and acted as an undercover agent for them. He assisted in several executions of suspected guerillas. He was charged of 7 counts of treason. He admitted to counts 1, 2, 3, and 7, but didn’t admit to counts 4, 5, and 6. The special prosecutor was only able to present evidence to support count 4.
HELD/RATIO: The accused was found guilty of treason for counts 1,2,3, and 7; but, he was acquitted for count 4. For counts 1, 2, 3, and 7, the accused was guilty since he admitted. However, he cannot be held liable for count 4 since the two-witness rule wasn’t met. The two witnesses testified to two different incidents. In a different light, common crimes are absorbed in treason. People vs. Adriano 78 Phil. 561 (1947) (Digest)
Two-Witness Rule in Treason
People vs. Adriano 78 Phil. 561 (1947)
Facts:
Between January and April, 1945, during the occupation of the Philippines by the Japanese Imperial Forces, in the Province of Nueva Ecija, the above-named accused, Apolinar Adriano, a Filipino citizen owing allegiance to the United States and the Commonwealth of the Philippines, giving the said enemy aid and comfort in the manner as a “member of the Makapili, a military organization established and designed to assist and aid militarily the Japanese Imperial Forces in the Philippines.
The prosecution did not introduce any evidence to substantiate any of the facts alleged except that of defendant's having joined the Makapili organization. What the People's Court found is that the accused participated with Japanese soldiers in certain raids and in confiscation of personal property. The acts of the accused had not been established by the testimony of two witnesses.
Issue:
Whether or not the two-witness rule is required in establishing the guilt of the accused in the crime of treason
Held:
Yes.
Ratio:
The two-witness rule required for conviction for treason is that no person shall be convicted thereof unless on the testimony of two-witnesses to the same overt act. If the overt act is separate, two (2) witnesses must also testify to each part of overt act for conviction.
