Title
People vs. Dizon
Case
G.R. No. L-923
Decision Date
Jun 24, 1949
Jose Dizon convicted of treason for aiding Japanese forces in WWII by arresting, torturing, and executing suspected guerrillas; sentenced to reclusion perpetua.

Case Digest (G.R. No. L-923)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The appellant, Jose Dizon, was accused of treason for aiding the Imperial Japanese Forces during the occupation of the Philippines.
    • The charges were based on his alleged active participation as an informer or agent of the enemy during various incidents in Santa Rosa, Laguna in 1943 and 1944.
  • Specific Acts Constituting the Charges
    • On or about August 2, 1943, the appellant participated in the arrest of Roman Malapitan, a suspected guerrilla member.
      • The arrest was carried out at approximately 6 o’clock in the afternoon.
      • Witnesses, including Maxima Dedicatorio (the widow of Malapitan) and neighbor Concha Pascual, testified to his involvement.
      • Roman Malapitan was subsequently turned over to the Japanese forces, who maltreated, tortured, and executed him.
    • On or about November 3, 1944, the appellant took part in the apprehension of Isidoro de los Angeles at a rice mill in barrio Balibago.
      • Isidoro, suspected of guerrilla activities, was arrested by a group that included the accused and Japanese personnel.
      • Testimonies from Gorgonio Cantos, Pantaleon Lara, and Amanda Lasaga established this arrest, after which Isidoro was beaten and later executed.
    • On or about November 16, 1944, multiple incidents occurred on the same day:
      • The arrest of Major Leopoldo F. Santos, a former USAFFE officer and guerrilla suspect, was confirmed by the appellant’s participation.
        • His participation was not denied during testimony.
      • The arrest of Roque Lazaga suffered from contradictory testimonies from his wife and daughter resulting in a benefit of the doubt to the appellant, which led to his acquittal on this count.
      • The arrest of Antonio Alumno and Jurado Alumno was similarly affected; only one witness testified, leading to acquittal on this count.
    • On or about November 24, 1944, the arrest of Lucio Aguilar was conducted in the presence of several persons.
      • Testimonies of Rosa Alinsod (Aguilar’s wife) and Federico Aguilar (his son) confirmed that the accused, armed and accompanied by persons in Japanese uniforms, participated in the arrest.
      • Lucio Aguilar was subsequently maltreated, tortured, and executed by the enemy.
    • In December 1944, the appellant voluntarily enlisted in the Makapili, a military instrumentality designed to collaborate with the Japanese forces.
      • His enlistment aimed to strengthen his support and active cooperation with the enemy.
      • He later evacuated with the Japanese into the mountains of Luzon and remained with them until his eventual capture by American and guerrilla forces.
  • Trial Court Proceedings and Findings
    • The trial court found the appellant guilty on all counts except for counts two and eight.
    • He was sentenced to reclusion perpetua, imposed a fine of P10,000, and ordered to pay the costs.
    • Evidence from multiple witnesses and documentary testimonies substantiated his involvement in the arrests and subsequent maltreatment of several guerrilla suspects.
  • Evidence and Witness Testimonies
    • The prosecution presented detailed testimonies from various witnesses who directly observed or were associated with the arrests.
    • Contradictions in some testimonies (as in the case of Roque Lazaga and the Alumno brothers) led to a beneficial doubt in favor of the appellant, resulting in acquittal on those specific counts.
    • However, for the counts where testimony was clear and consistent—especially regarding Roman Malapitan, Isidoro de los Angeles, Major Santos, and Lucio Aguilar—the evidence was deemed sufficient to uphold the conviction.

Issues:

  • Determination of Liability Under the Charge of Treason
    • Whether the appellant’s actions, as an informer and participant in the apprehension of guerrilla suspects, constituted treason under Article 114 of the Revised Penal Code.
    • The legal adequacy of the evidence presented in proving beyond reasonable doubt that the accused aided and comforted the enemy through his actions.
  • Evaluation of Contradictory Testimonies
    • How the discrepancies in witnesses’ testimonies for certain counts (notably involving Roque Lazaga and the Alumno brothers) affected the overall conviction.
    • Whether the benefit of the doubt should extend to those counts where evidence was conflicting.
  • The Applicability of the Makapili Enlistment
    • If the voluntary enlistment and service with the Makapili in December 1944 further established treason beyond the immediate acts of apprehension.
    • The legal implications of aiding the enemy by collaborating with Japanese forces in retreat and continued resistance against American and guerrilla forces.
  • Sufficiency and Reliability of Witness Testimonies
    • Whether the collected witness testimonies provided a complete and reliable account of the appellant’s participation.
    • The role of corroborative evidence in balancing contradictory witness accounts and establishing guilt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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