IN RE: Appeals from the People's Court

Approximately forty treason cases were originally appealed from the People’s Court to the Supreme Court.
The People’s Court, under Commonwealth Act No. 682, had the jurisdiction to try crimes against national security and decide upon any crime alleged in the information, regardless of the penalty imposed.
At the time of the enactment of Act No. 682 in September 1945, the Court of Appeals had been abolished (by Executive Order No. 37 of March 10, 1945), which made the People’s Court decisions directly appealable to the Supreme Court.

Republic Act No. 52, approved on October 4, 1946, re-created the Court of Appeals and conferred upon it exclusive appellate jurisdiction over all cases “not falling within the exclusives appellate jurisdiction of the Supreme Court.”
Section 3 of Act No. 52 provided that pending cases, falling under the appellate purview defined by the revived provisions of Commonwealth Act No. 682, be certified from the Supreme Court to the Court of Appeals.
The Judiciary Act of 1948 (No. 296) further clarified that:

The Supreme Court maintained exclusive appellate jurisdiction over criminal cases where the penalty was death or life imprisonment, or in cases involving additional offenses arising from the same occurrence.
Conversely, the Court of Appeals retained exclusive appellate jurisdiction over all other criminal cases (i.e., those with penalties less than death or life imprisonment).

With the complete restoration of the appellate jurisdiction of the Court of Appeals as provided by the Judiciary Act of 1948, it was argued that treason cases—imposing a penalty less than death—should be certified to the Court of Appeals.
Section 31 of the Judiciary Act authorized the transfer of any case erroneously brought to the Supreme Court or the Court of Appeals to the proper court.
The People’s Court is viewed as having the category of a court of first instance, more limited in jurisdiction compared to the general jurisdiction of the Courts of First Instance.

Republic Act No. 311 abolished the People’s Court and transferred pending cases to the respective Courts of First Instance, where appeals would be made to the Court of Appeals or the Supreme Court based on the applicable penalty.
The fact that cases decided after the abolition of the People’s Court were to be appealed through the Court of Appeals reinforced the argument against retaining unresolved treason cases in the Supreme Court.
The statutory provisions indicated that retaining treason cases for direct appeal to the Supreme Court would result in anomalous treatment compared to similar cases transferred from the People’s Court after its abolition.

The majority opinion by Justice Paras held that the treason cases belonged under the exclusive appellate jurisdiction of the Court of Appeals and should be properly certified there.
Concurring opinions (e.g., by Justice Perfecto) recognized the objection raised at the time of certification yet did not see a compelling legal reason to keep these cases with the Supreme Court.
Dissenting opinions by Justices Feria and Moran argued that:

A clear distinction existed between the People’s Court and the traditional Courts of First Instance.
The People’s Court was created as a special, collective court to try treason cases and its decisions were originally appealed solely to the Supreme Court.
The statutory scheme and the historical context should favor maintaining the established appellate procedure for People’s Court decisions, emphasizing that the change in appellate jurisdiction should not affect pending appeals.

Whether treason cases, originally decided by the People’s Court and appealed to the Supreme Court, should remain under the Supreme Court’s appellate jurisdiction, or be transferred (certified) to the Court of Appeals.
Whether the transformation in the appellate jurisdiction, evidenced by the re-creation of the Court of Appeals and the enactment of the Judiciary Act of 1948, conclusively transfers jurisdiction over treason cases (with penalties less than death or life imprisonment) from the Supreme Court to the Court of Appeals.

How to interpret the provisions of Commonwealth Act No. 682, Republic Act No. 52, and the Judiciary Act of 1948 regarding the appellate jurisdiction over treason cases.
Whether legislative intent in subsequent acts, particularly Republic Act No. 311, implicitly or expressly addressed the treatment and appeal of treason cases already decided by the People’s Court.

Whether allowing the Supreme Court to review these treason cases would create disparities compared to treason cases decided by Courts of First Instance after the abolition of the People’s Court.
The implications of transferring pending appeals post-abolition versus maintaining the status quo for cases already certified to the Supreme Court before the legislative changes.