Case Digest (G.R. No. L-23465)
Facts:
People of the Philippines v. Casto Alejandrino, G.R. No. L-23465, October 31, 1979, Supreme Court Second Division, Fernando, C.J., writing for the Court.The defendant-appellant, Casto Alejandrino (also known by several aliases), was convicted by the trial court for violation of Republic Act No. 1700 (the Anti-Subversion Act). The trial judge was Conrado V. Vasquez, whose written conviction was later appealed to the Supreme Court. The prosecution presented essentially all the evidence; after the prosecution rested, Alejandrino waived the presentation of testimonial evidence in his own defense and relied only on Exhibits 1 to 6 admitted into evidence.
Among the prosecution evidence was a written petition the accused read in court on February 15, 1962 (marked Exhibit C for the prosecution and adopted as Exhibit 2 for the defense) in which the accused expressly stated his membership in the Party outlawed by RA No. 1700 and sought postponement of the trial pending a Supreme Court decision on the statute’s constitutionality. The petition, though unsigned by the accused, was adopted into the record and treated as an admission of membership after the statute’s effectivity (RA No. 1700 was approved June 20, 1957).
Prosecution witnesses testified to overt acts attributed to Alejandrino. Multiple witnesses—Ricardo Mendoza, Juan Singian, Melencio Guevarra and Exequiel Santiago—testified that Alejandrino presided over a Huks conference at Telabastagan, Angeles, Pampanga in the first week of March 1958, and that he led a group in an armed encounter with government troops there in the last week of March 1958, where he allegedly carried and fired two firearms and exhorted his men to fight. Two former Huks, Lazaro Esteban and Rufino Aqueza, testified to Alejandrino’s presence at a Huks conference in Biak-na-Bato, San Miguel, Bulacan in November 1957. The trial court found these testimonies and the admission sufficient to satisfy the evidentiary and two-witness requirements for conviction under the statute and rendered judgment accordingly.
Alejandrino appealed, challenging the constitutionality of RA No. 1700 (arguing ex post facto application and violation of freedoms of spee...(Pro-only)
Issues:
- Is Republic Act No. 1700 (the Anti-Subversion Act) unconstitutional as violative of the prohibitions against ex post facto laws and of the freedoms of speech and peaceable assembly?
- Did the prosecution fail to meet the two-witness rule and otherwise present evidence sufficient to convict Casto Alejandrino...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)