Laurel vs Misa

Facts:

Anastacio Laurel filed a petition for habeas corpus arguing that as a Filipino
citizen, adhering to and aiding the Japanese enemy during their occupation
of the Philippines should not be considered treason, as.the sovereignty of the
legitimate Philippine government was suspended.

Issue:

Whether the sovereignty of the legitimate Philippine government was

Ruling:

No. The court held that the sovereignty of the legitimate Philippine
government was not suspended during the Japanese occupation, as the
absolute and permanent allegiance of Filipino citizens remains with their
legitimate government, even when the territory is occupied by an enemy.

Estrada v. Sandiganbayan

Facts:

Five criminal complaints were initiated with the Ombudsman against former
President Estrada and others. The Ombudsman found probable cause,
recommending the indictment for various offenses, including plunder under
Republic Act No. 7080 against Jose ‘Jinggoy’ Estrada. A criminal Information
was filed, for plunder, divided into sections detailing various acts of the
conspirators. Estrada sought to quash the Information and suspend
proceedings, arguing that the Plunder Law was unconstitutional and the
Information charged more than one offense. Despite these motions, an arrest
warrant was issued, placing Estrada in custody. A series of motions were filed
on Estrada’s behalf, often overlapping on issues of probable cause,
constitutional challenges, and the right to bail. The Sandiganbayan denied
Estrada’s motions, paving the way for his arraignment where he pleaded not
guilty following the court’s entry. Estrada then filed a petition with the
Supreme Court, challenging Sandiganbayan’s decisions on numerous
constitutional and procedural grounds.

Issue:
Whether or not the charge against petitioner be dismissed on the ground
that the allegation of conspiracy in the Information is too general.

Ruling:

No. The Court deemed that the Information filed was sufficiently detailed to
comply with legal standards, asserting it captured the requisite elements,
including series or combination in its phrasing, that pointed towards the
aggregation element vital under the plunder law. The Supreme Court held
that the allegation of conspiracy in the information was not too general.For
the crime of plunder, different parties may be united by a common purpose
to help the former President amass wealth illegally. The information alleged
the different participation of each accused in the conspiracy sufficiently
without needing to

Describe the conspiracy with the same particularity as a substantive offense.

People v. Abad

Facts:

Francisco Abad was found guilty with three (3) counts of treason by giving
aid and comfort to the Empire of Japan and the Japanese Imperial Forces. In
the first count,the prosecution presented as witnesses Magno lbarra and his
wife, Isabel. Isabel testified that Francisco, accompanied by his brother and
Japanese soldiers, went to their house and demanded Magno’s surrender of a
revolver. At the time, Magno was not at the house. Moreover, Magno testified
that Francisco demanded him to produce the revolver while at the garrison.
In his appeal,Francisco raised that the lower court erred in finding him guilty
on the first count because there was only a single witness, respectively, to
the overt acts of treason alleged. Magno could not corroborate Isabel’s
statement as to Francisco’s coming to their house because Magno was not
there at the time. Also, Isabel could not corroborate Magno’s statement that
Francisco demanded the former to produce the revolver at the garrison
because she was not there at the time. The Solicitor General advances the
theory that where the overt act is simple, continuous, and composite, made
up of, or proved by several circumstances, and passing through stages, it is
not necessary that there should be two (2) witnesses to each circumstance
at each stage.

Issue:
Whether or not the theory of the Solicitor General is correct.

Ruling:

No. The Court ruled that the prosecution did not meet the two-witness rule
for the first count. While the acts may have had the same purpose,
demanding a revolver at someone’s house and demanding it again
elsewhere were two separate overt acts that each required two witnesses. As
there was only one witness for each act,the first count was not sufficiently
proven.

US v Lagnason

Facts;

Dalmacio Lagnason and his band of 70-80 men attacked the town of Murcia
in the Philippines. The Constabulary engaged Lagnason’s band in a battle,
killing around 20 men and capturing Lagnason. The lower court found
Lagnason guilty of treason and sentenced him to death. The case was
appealed to the Supreme Court of the Philippines.

Issue:

Whether Lagnason’s acts constituted treason.

Ruling:

Yes. The Court held that Lagnason was guilty of treason as defined in Act No.
292, as his organized attempt to overthrow the established US government
in the Philippines through violence amounted to levying war against the
government.

People v. Bate

Facts:

Bate was found guilty on six counts of treason. On one count, the appellant
who was then armed and who was accompanied by several undercover men
arrested Francisca Bacalla and took her to Sgt.Yoshida, chief of the Japanese
Military Police,where she was investigated and maltreated. As pointed out by
the Solicitor General, only one witness FelisaTaboado testified as to Bacalla’s
arrest by the appellant and only one witness,ConradoBao, the cook of Sgt.
Yoshida testified about her investigation at Yoshida's house by the defendant.
Issue:

Whether or not the appellant be held guilty of treason..

Ruling:

Yes. The Court ruled that, though not sufficient to prove the overt acts of
which Bate is accused, nevertheless, the evidence may be considered as
proof of his adherence to the enemy. The court's decision was based on
substantial evidence by the prosecution, including corroborated testimonies
from at least two witnesses for each count, establishing Bate’s participation
in treasonable acts. Bate was consistently seen armed and with Japanese
soldiers, playing key roles in raiding parties, apprehending, and torturing
individuals. The defense’s claims and witness testimonies were found less
credible compared to the prosecution’s evidence.

People v Pordales

Facts:

Issue:

Ruling:

People v. Morales

Facts:

Lorenzo Morales, charged with treason during the Japanese occupation of the
Philippines. He acted as a guard, armed with a firearm, during a raid by
Japanese soldiers and Makapili members. The raid led to the capture, torture,
and death of several guerrillas, including Maximo Ramos, Alejo Velayo, Rufino
Velayo, Ricardo Velayo, Fermin Chico, Bonifacio de Jesus, and Arsenio
Pacheco. The Court of First Instance of Bulacan found Morales guilty of
treason. Morales was sentenced to 20 years of reclusion temporal and fined
P10,000, plus costs. Morales appealed the decision.

Issue:

Whether or not Morales is a Filipino citizen to be charged of treason.

Ruling:
Yes. The Court held that the appellant’s Filipino citizenship is proven by
certified true copies of his identification record card and certificate of
citizenship, the originals of which are on file on the Bureau of Prisons. Also,
Morales’ presence was significant as he was armed and acted as a guard
during the raid. Carrying a firearm in the presence of Japanese soldiers
indicated collaboration with the enemy. The court referenced People vs.
Capacete, which established that openly carrying a firearm while
accompanying Japanese soldiers indicated collaboration.

People v Villanueva

Facts:

Appellant gave the enemy aid and comfort by rendering service with the
Japanese Imperial Army as secret agent,informer and spy, of its Detective
Force in the province of lloilo. The appellant put up the defense of duress
allegedly exerted by the Japanese upon him for which he had to serve in the
detective force of the Japanese Army.

Issue:

Whether or not the appellant be held guilty of treason.

Ruling:

Yes. The Court held that, except the lone and self-serving testimony of the
appellant that he was coerced to cooperate with and serve the Japanese
soldiers, there is not an iota of proof that he was in fact compelled or coerced
by the Japanese. Much less is there any evidence showing that the alleged
compulsion orcoercion was grave and imminent.

People v. Racaza

Facts:

Antonio Racaza, a Filipino citizen, was accused of aiding the Empire of Japan
during World War II by acting as a spy and participating in acts of cruelty and
violence against suspected guerrillas and their supporters. Specific charges
included leading Japanese patrols to apprehend and torture guerrilla
suspects, participating in torture and killings, attempted rape, and robbery.
The trial court found Racaza guilty on 14 counts of treason and sentenced
him to death, a fine of P20,000, and costs. The trial was not in strict
accordance with legal procedures, leading to confusion and errors. Racaza
initially pleaded guilty to some counts but changed his plea to guilty for all
14 counts after further testimony. Despite his guilty plea, Racaza later denied
some charges and provided explanations for others, leading the court to rely
on prosecution evidence and his admissions. The trial court found
aggravating circumstances of evident premeditation, superior strength,
treachery, and employment of means for adding ignominy to the crime.

Issue:

Whether or not the trial court is correct.

Ruling:

No. The Supreme Court found these circumstances inherent in treason and
could not be used to aggravate the penalty, except for acts of cruelty like
rapes and wanton robbery. The court acknowledged that a plea of guilty,
even if entered after some evidence has been presented, should be
considered a mitigating circumstance under paragraph 10 of Article 13 of the
Revised Penal Code. This provision allows for any circumstance of a similar
nature and analogous to those specified as mitigating circumstances to be
considered in the judgment.

People v. Icaro

Facts:

Eleuterio Icaro, a Filipino citizen, is accused of treason for openly adhering to

Issue:

Whether or not Icaro is guilty of treason.

Ruling:

Yes. The court upholds the treason conviction, as Icaro’s overt acts of
assisting in arrests of guerillas who then disappeared, while armed and with
Japanese soldiers, demonstrates adherence to the enemy.