Case Digest (G.R. No. L-1006)
Facts:
The People of the Philippines v. Filemon Escleto, G.R. No. L-1006, June 28, 1949, the Supreme Court En Banc, Tuason, J., writing for the Court. The People of the Philippines (plaintiff and appellee) charged Filemon Escleto (defendant and appellant) in the former People’s Court with treason on three counts for acts alleged during the Japanese occupation: (1) fraternizing and bearing arms with Japanese forces on patrols, (2) accompanying Japanese soldiers on patrols in search of guerrillas, and (3) arresting and turning over one Antonio Conducto to Japanese authorities on or about March 18, 1944.At trial the People’s Court reviewed testimony from witnesses who described that, following a guerrilla ambush in barrio Bibito, many inhabitants were ordered to report to poblacion; among them was Conducto. Two witnesses, Sinforosa Mortero and Patricia Araya, testified that Escleto took down the names of Conducto and other family members in front of Escleto’s house and accompanied them to the Philippine Constabulary (PC) garrison where they were questioned; Conducto was not released the following day and was never heard from again. Patricia Araya also testified that Escleto told a PC soldier, “This is Antonio Conducto who has firearm.”
The People’s Court found the prosecution had not produced “concrete evidence” of membership in U.N. or Makapili organizations nor shown what the patrols actually did, and therefore ruled that counts 1 and 2 failed to establish any true overt act of treason; however, it held that the evidence sufficiently proved Escleto’...(Pro-only)
Issues:
- Did the prosecution prove, beyond reasonable doubt and in compliance with the treason two-witness rule, the overt acts charged in counts 1 and 2?
- Did the prosecution sufficiently prove the overt act charged in count 3 (that Escleto arrested or caused the arrest of Antonio Conducto and delivered him to Japanese authorities)?
- Does the lack of corroboration and the character of the evidence require reversal of the conviction(...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)