People v. Mateo
REITERATIONFacts
The Antecedents: The appellant, Pastor Tan Mateo, a native citizen of the Philippines, was charged with treason. The prosecution presented evidence that from June 1942 to March 1945, the appellant was employed in the Public Opinion Office in Dumaguete, Oriental Negros, an organization that gathered information for the Japanese Army regarding guerrilla movements and activities. In this capacity, the appellant observed and gathered information about guerrillas and reported his findings to Teodorico Lajato or Major Bartolome Soledad, the Chief of Police. Specifically, on March 28, 1943, the appellant reported his suspicion that Alfonso Calubiran and Antonio Chan were in league with the guerrillas, leading to their apprehension, imprisonment, investigation, and ill-treatment. Subsequently, in October 1944, the appellant participated in the apprehension of Angeles Catan, who was taken to the Kempei Tai headquarters. The appellant admitted to being employed in the Public Opinion Office but denied being an informer or causing the arrests. Procedural History: The appellant was tried, found guilty of treason by the trial court, and sentenced to 15 years of reclusion temporal, a fine of P2,000, and costs. He appealed the judgment. The Petition: The appellant appealed the decision of the trial court, challenging his conviction for treason.
Issue(s)
Whether the testimony regarding the appellant's general activities and employment as an informer satisfies the two-witness rule for an overt act of treason. Whether the arrest of Alfonso Calubiran and Antonio Chan on March 28, 1943, was proven by the required quantum of evidence to constitute a treasonous overt act. Whether the arrest of Angeles Catan in October 1944 qualifies as a treasonous overt act.
Ruling
The Supreme Court affirmed the conviction of the appellant for treason, with modifications regarding the application of the two-witness rule to specific overt acts. The Court held that while the appellant's general activities might show adherence to the enemy, the arrest of Calubiran and Chan, which was directly instigated by the appellant's report, constituted a treasonous overt act proven by more than two witnesses. The arrest of Angeles Catan was not deemed treasonous due to insufficient evidence regarding its purpose and Catan's role. The penalty imposed by the trial court, considering the mitigating circumstance of lack of instruction, was affirmed as it fell within the range provided by law.
Ratio Decidendi
On Issue 1: The Court held that the evidence regarding the appellant's general employment and information-gathering activities was insufficient to satisfy the two-witness rule. While several witnesses testified to having seen the appellant at the Public Opinion Office and observed him going around town, no two of them referred to the same specific overt act or activity on the same occasion. The two-witness rule requires identity in the act witnessed; it is not enough that the witnesses saw similar acts at different times. However, these testimonies were not useless as they were taken into consideration to prove the appellant's 'adherence to the enemy.' Adherence, which is the traitor's intent to betray his country, does not require the same level of proof as the overt act itself. On Issue 2: The Court ruled that the arrest of Alfonso Calubiran and Antonio Chan on March 28, 1943, was a treasonous overt act proven in accordance with the law. This specific incident was witnessed by four persons: Alejandro Lazola, Antonio Chan, Alfonso Calubiran, and Pedro Gadiani. The appellant initiated the arrest by informing the Chief of Police of his suspicions that the victims were guerrilla runners, which led to their apprehension and subsequent ill-treatment. Since at least two witnesses testified to this same physical act, the evidentiary requirement for an overt act was met. This act clearly provided aid and comfort to the enemy by suppressing the resistance movement. On Issue 3: The Court found that the arrest of Angeles Catan did not qualify as a treasonous overt act. The evidence showed that Catan was released only one day after his arrest, and there was testimony suggesting Catan might have been an undercover operative for the pro-Japanese organization himself. Treason requires that the act performed by the accused must effectively provide aid and comfort to the enemy and harm the interest of the home country. Given the ambiguity of the circumstances and the quick release of the victim, the prosecution failed to establish the treasonous nature of this specific act. Consequently, this count was excluded from the basis of the conviction.
Main Doctrine
The crime of treason requires proof of adherence to the enemy and an overt act, both of which must be established by the testimony of at least two witnesses. While general activities may show adherence, specific overt acts, such as participating in the arrest of individuals suspected of aiding guerrillas, must be proven by two witnesses to satisfy the legal requirement.