People v. Pacheco
REITERATIONFacts
The Antecedents: Maximo Pacheco was tried for treason in the Court of First Instance of Bulacan. The amended information alleged two counts: (1) acts performed in Polo, Bulacan, involving the arrest, maltreatment, and shooting of Ceferino Rivera on January 2, 1945; and (2) acts performed in Manila in February 1945, involving the arrest and torture of Judge Eugenio Angeles, whom Pacheco allegedly identified to the Japanese as a guerrilla major. Procedural History: The Court of First Instance of Bulacan found Pacheco guilty as charged and sentenced him to life imprisonment, a fine of P10,000, and to indemnify the heirs of Ceferino Rivera in the amount of P6,000. Pacheco appealed. The Petition: The accused appealed, assigning four errors that raised two principal issues: the jurisdiction of the second court to try the second count, and the credibility of the witnesses.
Issue(s)
Whether the Court of First Instance of Bulacan had jurisdiction to try the accused for overt acts committed in the City of Manila. Whether the evidence presented by the prosecution, specifically the testimonies of the witnesses, was sufficient to prove the overt acts of treason under the two-witness rule.
Ruling
The appealed decision is affirmed. The accused-appellant is found guilty of treason.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court's jurisdiction was proper because treason is a continuous offense. Relying on Guinto v. Veluz, the Court explained that treason may be committed by executing either a single or several intentional overt acts, but it remains one single offense. Under Section 9, Rule 106 of the Rules of Court, a continuous offense can be prosecuted in any province where some of its essential ingredients occurred. The Court rejected the appellant's interpretation of Republic Act No. 311, stating that the transfer of cases from the People's Court to the Courts of First Instance was not intended to disturb usual rules on jurisdiction or venue. Upholding the appellant's contention would lead to the undesirable result of allowing multiple separate prosecutions for the same offense in different provinces. Therefore, since a material part of the treasonous activity occurred in Bulacan, that court could validly take cognizance of the related acts in Manila. On Issue 2: The Court ruled that the testimonies provided by the prosecution were credible and satisfied the two-witness rule for the material overt acts. Regarding the first count, the arrest of Ceferino Rivera was witnessed by his father and wife, while his execution was witnessed by multiple neighbors who identified Pacheco as the shooter. The Court brushed aside minor inconsistencies in the testimony of the victim's wife, stating they referred to unsubstantial matters that did not destroy her overall veracity. As to the second count, while only Judge Angeles testified to the actual torture, the material overt act of his apprehension as a guerrilla suspect was witnessed and related in open court by his son and a doctor. This collective testimony met the legal requirement that each overt act of treason be proven by at least two witnesses. The Court further noted that Pacheco's claim of being a guerrilla himself was not a valid defense against his proven overt acts of aiding the enemy, consistent with the rulings in People v. Victoria and People v. Castillo.
Main Doctrine
Treason is a single offense that may be committed by several distinct overt acts occurring in different provinces, and can be prosecuted in any province where any material ingredient of the offense occurred. The claim of being a guerrilla is not a defense against overt acts of treason.