People v. Golez
REITERATIONFacts
The Antecedents: The accused, Romeo Golez, a Filipino citizen, was convicted of treason on three counts (3, 4, and 7) by the Court of First Instance of Occidental Negros. He was sentenced to 20 years of reclusion temporal, a fine of P10,000, and accessory penalties. The case was certified to the Supreme Court by the Court of Appeals due to the penalty imposed. Procedural History: The accused appealed his conviction to the Court of Appeals, which then certified the case to the Supreme Court. The Supreme Court reviewed the evidence presented against the accused. The Petition: The accused appealed his conviction, denying participation in the arrests and imputing them to Juanito Diaz. He also claimed to have been a guerilla.
Issue(s)
Whether the evidence established the overt acts of treason committed by the accused. Whether the testimonies of the witnesses complied with the two-witness rule for treason. Whether the accused's prior connection with the guerilla movement excused his subsequent treasonable activities.
Ruling
The Supreme Court affirmed the conviction of the accused for treason, modifying the sentence to life imprisonment. The Court found that the charges in the three counts were established by the required number of witnesses and that the testimonies agreed on the overt acts of treason committed by the accused.
Ratio Decidendi
On whether the evidence established the overt acts of treason committed by the accused: The Court found that the testimonies of the witnesses, when taken together, established the overt acts of treason. Specifically, for Count 3, Mrs. May Estella Gay testified that the accused apprehended her and her sister, charging them with aiding the guerillas, leading to their investigation and maltreatment by the Kempeitai. Dominador Gavino corroborated this arrest. For Count 4, Filomeno Gino-o testified that the accused, with Juanito Diaz, arrested him and accused him before the Kempeitai of being a mechanic for the guerillas, resulting in his torture. His wife, Felipa de Gino-o, corroborated the arrest and testified to his contusions. For Count 7, Vicente de la Cruz testified that the accused led a Kempeitai officer to arrest Manuel Chua, a guerilla, who was never seen again. Jose Coswanko corroborated the arrest, and Higino Lopez saw Manuel Chua tied and accompanied by the accused and others. Enrique Chua testified that his brother Manuel was buried after his apprehension. On whether the testimonies of the witnesses complied with the two-witness rule for treason: The Court held that while there may not be complete corroboration between prosecution witnesses on all points, their testimonies agreed on the overt acts of treason committed by the accused. This agreement on the overt acts is sufficient compliance with the two-witness rule, citing People vs. Francisco Concepcion. The Court found no reason to disturb the trial court's findings on credibility, especially since the accused did not provide a motive for the accusers to testify falsely. On whether the accused's prior connection with the guerilla movement excused his subsequent treasonable activities: The Court ruled that a prior connection with the guerilla movement does not preclude an individual from becoming a tool of the Japanese. The Court reiterated its holding in People vs. Atilares that a connection with the guerilla movement is not a legal excuse for treasonable activities. Therefore, the accused's claim of having been a guerilla did not absolve him of the treasonous acts he committed while working for the Japanese.
Main Doctrine
Active participation in the arrest of persons connected with the guerillas, even if the accused was formerly a guerilla, constitutes overt acts of treason, satisfying the two-witness rule when testimonies agree on such overt acts.