People vs.

Manayao 78 Phil 721

Contention of the State: The three accused were charged with treason complexed with
multiple murder in the People’s Court. They participated in the massacre of several citizens who
were suspected to have been helping the guerillas.

Defense of the Accused: The accused claimed that they cannot be tried since the Court has no
jurisdiction. Furthermore, they claimed that they had renounced their Filipino citizenship after
joining the Japanese paramilitary Makapili, and then swearing allegiance to Japan

Ruling of the Supreme Court:

The accused were found guilty. The Makapili is not a part of the Japanese army. It was an
organization of Filipino traitors. Moreover, there is no evidence that the accused swore to an
oath of allegiance when they entered the said organization. Furthermore, it is the lone
prerogative of the State to allow or deny one’s change of citizenship.The oath of the Makapili
members was only a sworn to help Japan in the war and not swearing to support its
constitution and laws. As stated in Article II, Sec. 2 of the 1935 Constitution “The defense of a
State is the prime duty of the government and the people, and in the fulfillment of this duty all
citizens may be required by law to render personal military or civil service.” This constitution
covers both time of peace and time of war that the citizen cannot be considered free to cast off
his loyalty and obligations toward the Fatherland.