People vs Manayao

Facts:

Pedro Manayao and Filomeno Flores and Raymundo Flores were charged with treason with multiple
murder and with aggravating circumstances of aid of armed men and the employment or presence of
a band. The two Floreses were not apprehended hence only Manayao was tried.

On January 27, 1945, the Japanese forces together with some Filipinos who were members of the
Makapili conceived the idea of killing the residents of Barrio Banaban, Angat as reprisal of the raid
conducted by the guerillas against the Japanese. Armed with rifles and bayonets, the culprits
assembled the residents behind a chapel wherein children were separated from men and women.
The group then proceeded to butcher the residents. Apellant alone killed six women, two of whom
were Patricia and Dodi whom he bayoneted to death in the presence of their daughters, Maria
Paulino and Clarita Perez, respectively. Apellant would have also killed the small children including
the latter but the Japanese spared the children on the ground that they know nothing of the matter.
Clarita and Maria Paulino were the star witnesses to the ruthless massacre. Apellant himself admitted
his participation in the massacre in two sworn statements.

Assignment of errors:

1. That the appellant was a member of the Armed Forces of Japan, was subject to military law, and
not subject to the jurisdiction of the People’s Court

2. That the appellant had lost his Philippine citizenship and was therefore not amenable to the
Philippine law of treason

SC ruling:

1. The Makapili although organized to render military aid to the Japanese in the Philippines during the
war, was not part of said army. It was an organization of Filipino traitors.

2. As to loss of citizenship, appellant invokes Commonwealth Act No 63:

a. By subscribing to an oath of allegiance to support the constitution or laws of a foreign country

upon attaining the age of 21 - there’s no evidence that the appellant had subscribed to an oath of
allegiance to the constitution or laws of Japan. Makapili members could have sworn to help Japan in
the war without necessarily swearing support her constitution and by laws.

b. By accepting foreign commission in the military, naval or air service of a foreign country - no
evidence that shows acceptance of the appellant of a commission in the Japanese military

c. By having been declared, by competent authority, a deserter of the Philippine Army, Navy or
Air Corps in time of war - no evidence of having been declared a deserter in the Philippine Army

3. The contention of the appellant is repugnant to the Constitution which provides that the defense of
the State is the prime duty of the government and that in the fulfillment of this duty the citizens may
be required to render personal, military or civil service. The constitutional provision covers both time
of peace and time of war. It is brought more immediately and peremptorily during war. During such
time, a citizen cannot be allowed to freely cast off his loyalty and obligations towards the State.

4. It is shocking to the conscience that the appellant having admitted the commission of the crime
and divested himself of Philippine citizenship had placed him beyond the arm of our treason law.

5. The aggravating circumstance of aid of armed men is considered absorbed in the band.

6. The contention that the appellant acted under an order of a superior is not tenable as the order is
illegal in itself. Also the appellant could not have acted under an impulse of irresistible force or
uncontrollable fear because he voluntarily joined the Makapili.

7. Reclusion Perpetua. Fine of 20,000. Indemnity of 2,000 to the heirs of each of the victims.

People vs Prieto

Facts: