People v. Reyes
REITERATIONFacts
The Antecedents: The appellant, a soldier in the Philippine Constabulary, surrendered with his unit to the Japanese army during the Pacific War and subsequently became a sergeant in the Bureau of Constabulary under the Japanese regime. On September 3, 1944, he participated with other undercover agents of the Japanese Army in the maltreatment and investigation of Teofilo Ponce and Tereso Saso regarding their connection with guerrillas. This occurred at Cabadiangan, Liloan, Cebu, where Ponce had been apprehended while the appellant and his group were searching for Governor Hilario Abellana. Later, Governor Abellana was arrested and killed by the Japanese. From Cabadiangan, Ponce and Saso were brought to Tamiao market, where Francisco, Evaristo, Epifanio, and Victorio Magdadaro were also arrested by the appellant's group. Francisco Magdadaro was killed on the spot by the appellant and his companions on the same day. Procedural History: The case originated from a criminal charge for treason against the appellant. The trial court found the appellant guilty of treason and sentenced him to suffer the penalty of reclusion perpetua and to pay a fine of P10,000 and costs. The Appeal: The defendant-appellant appealed the decision of the trial court, challenging his conviction for treason. The primary defense presented was alibi, with the appellant claiming he was in the constabulary barracks in Barili, serving as mess sergeant and engaged in buying foodstuffs in the market at the time the alleged offenses occurred. To support this alibi, the appellant presented witnesses, including Florentino Villarta, Jose Alviar, and Ambrosio Velasquez.
Issue(s)
Whether the evidence presented conclusively proves that the appellant committed the crime of treason under Article 114 of the Revised Penal Code. Whether the alibi presented by the appellant is sufficient to acquit him of the charges.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the appellant guilty of treason. The Court held that the facts proved by the evidence on record conclusively showed that the appellant adhered to the enemy by giving them aid and comfort, thereby committing the crime of treason, punishable under Article 114 of the Revised Penal Code. The sentence of reclusion perpetua and a fine of P10,000 and costs was affirmed.
Ratio Decidendi
On Whether the evidence presented conclusively proves that the appellant committed the crime of treason under Article 114 of the Revised Penal Code: The Court found that the testimonies of Teofilo Ponce and Tereso Saso, who were victims of the appellant's actions, conclusively proved the appellant's participation in the maltreatment and torture of Ponce and Saso, as well as the killing of Francisco Magdadaro. These acts were performed while the appellant was serving under the Japanese regime, demonstrating adherence to the enemy and the provision of aid and comfort. The Court noted that the appellant's membership in the Bureau of Constabulary during the Japanese regime was partly corroborated by the appellant himself and his witnesses. The testimonies of the prosecution witnesses were not questioned regarding their motives, and there was no reason to doubt their veracity. The Court concluded that these proven facts conclusively showed the appellant adhered to the enemy, thus committing treason. On Whether the alibi presented by the appellant is sufficient to acquit him of the charges: The Court found the alibi presented by the appellant to be completely unbelievable and insufficient to overcome the evidence of his guilt. The appellant claimed he was in the constabulary barracks in Barili, serving as mess sergeant and buying foodstuffs in the market. However, the testimony of Jose Alviar, who claimed to be in command of the barracks and stated the appellant never left his company, was deemed an "index of the nature of the testimonies presented by appellant in support of his alibi." The Court found this testimony to be an exaggerated attempt to make the alibi appear air-tight, rendering it incredible. Furthermore, the testimony of Ambrosio Velasquez, even if accepted, would not belie the appellant's participation in the torture and killing. Therefore, the alibi was rejected.
Main Doctrine
The crime of treason under Article 114 of the Revised Penal Code is committed by any person owing allegiance to the Government of the Philippines who levies war against it or adheres to its enemies, giving them aid and comfort within the Philippines or elsewhere. The evidence presented conclusively showed that the appellant adhered to the enemy by giving them aid and comfort, thus committing the crime of treason.