Case Digest (G.R. No. 203080)
Facts:
In People v. Apolinar Adriano, G.R. No. L-477, decided June 30, 1947, the accused, Apolinar Adriano, a Filipino citizen owing allegiance to the United States and the Commonwealth of the Philippines, was charged with treason before the People’s Court. The information alleged that between January and April 1945, during the Japanese occupation of Luzon, he willfully adhered to the military forces of Japan by joining the Makapili, an organization established to collaborate with the Japanese Imperial Forces. The prosecution’s evidence consisted solely of testimony that Adriano wore a Makapili uniform, carried a rifle, drilled under Japanese instruction, served as sentry at the Gapan garrison, and retreated with Japanese forces upon liberation. No two witnesses corroborated any specific overt act of treason. At trial, the People’s Court found membership in Makapili sufficient proof of adherence, convicted Adriano of treason, and sentenced him to lifeCase Digest (G.R. No. 203080)
Facts:
- Case Background
- The People of the Philippines filed an information charging Apolinar Adriano with treason for having “adhered to the Military Forces of Japan,” giving aid and comfort during the Japanese occupation (Jan–Apr 1945) in Nueva Ecija and Luzon.
- The People’s Court convicted Adriano of treason and sentenced him to life imprisonment, a ₱10,000 fine, and costs.
- Trial Court Proceedings and Findings
- Prosecution evidence focused on Adriano’s membership in the Makapili, a pro-Japanese militia:
- Witnesses saw him in Makapili uniform bearing arms on various occasions.
- No two witnesses testified to the same specific overt act.
- The trial court—applying the two-witness rule—found only membership proved and deemed alleged participation in raids, drills, sentry duties, and seizures as merely circumstantial evidence of adherence to the enemy.
Issues:
- Two-Witness Requirement
- Whether the testimony of two witnesses who each saw Adriano in Makapili uniform on different days satisfies the constitutional rule requiring two witnesses to the same overt act of treason.
- Sufficiency of Membership as Overt Act
- Whether mere membership in the Makapili constitutes an overt act of treason and if so, whether it must be proven by two witnesses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)