Case Digest (G.R. No. 179669)
Facts:
The case revolves around Eugenio Escosura, who faced six counts of treason following allegations that he actively collaborated with Japanese forces during their occupation of the Philippines in World War II. On November 2, 1948, the Supreme Court rendered its decision in G.R. No. L-1291, affirming the conviction by the People’s Court. Testimonies against Escosura detailed his involvement in two specific instances of treason.
In the first instance, on October 8, 1943, Jose de Castro, a municipal policeman in Sta. Rosa, Laguna, recounted that he and several colleagues were arrested by Japanese soldiers aided by Filipinos, including Escosura. The police were taken to a nearby Japanese garrison where they were interrogated regarding their guerrilla activities. De Castro identified Escosura as a collaborator, noting that he was armed with a rifle. Other witnesses, including Adolfo Bascon, corroborated De Castro's testimony about seeing Escosura armed and collaborating with the
Case Digest (G.R. No. 179669)
Facts:
- Arrest and Detention of Policemen (Count One)
- Testimony of Jose de Castro, a municipal policeman of Sta. Rosa, Laguna:
- On October 8, 1943, at about two o’clock in the afternoon, Japanese soldiers, accompanied by about eight Filipinos (including the accused, Eugenio Escosura), unexpectedly arrived at the municipal building.
- The group arrested de Castro along with six other policemen.
- The Filipinos arrested were armed; notably, Escosura was seen carrying a rifle.
- The prisoners were taken in a truck to the Japanese garrison in Calamba and were interrogated regarding guerrilla activities.
- During detention, the prisoners were forced to dig holes, purportedly intended for their burial, and were held for forty-one days before being set free.
- Additional Observations:
- De Castro testified that he saw Escosura with Japanese soldiers on several other occasions, always carrying arms.
- The accused and other Filipinos were described as makapilis, having used Arsenio Batitis’ house in barrio Aplaya, Sta. Rosa, as their headquarters.
- Corroborating Testimony by Adolfo Bascon:
- Confirmed the arrest, detailing that both de Castro and others were questioned multiple times, including instances involving Japanese officers and Arsenio Batitis.
- Noted a discrepancy regarding the exact composition of the group sent to Calamba, where Bascon claimed that Batitis, Escosura, Rafael Batitis, and Victorio Gardoce were the ones who went together, explicitly mentioning that they were makapilis by virtue of wearing Japanese uniforms and bearing arms.
- The Kidnapping and Death of Major Leopoldo Santos (Count Two)
- Testimony of Candelaria M. Santos:
- Stated that her husband, Major Leopoldo Santos, was arrested on November 16, 1944, around three o’clock in the morning in their house in barrio Pooc, Sta. Rosa.
- He was awakened by his wife when Japanese troops, accompanied by Filipinos (including the accused), broke into their house through a window.
- The raiders, some in Japanese uniform and others in civilian attire, searched the house leading to the apprehension of Major Santos who then jumped out the window to escape.
- Major Santos, despite his escape attempt, was wounded by bayonet stabs, had his hands tied after being dressed by his wife (with permission from the Japanese), and was thereafter bound and taken away.
- His remains were only recovered on June 27, 1945.
- Testimony of Pablo Alumno:
- Recounted that on the early hours of November 16, 1944, he witnessed the accused leading a group of men toward Major Santos’ house.
- He observed a truck arriving near the house and saw the accused alongside other Filipinos at the gate.
- Noted Major Santos’ dramatic escape by jumping out of the window, climbing an avocado tree, and subsequently being captured after shouting in pain.
- Described seeing the accused holding a rifle with a fixed bayonet near the scene where Major Santos was tied and carried away by two men.
- Defense Testimonies and Other Witness Accounts
- Testimonies from various witnesses:
- The accused, Eugenio Escosura, vehemently denied the acts he was charged with.
- Valentin de los Reyes and Antonio Patapat provided statements that neither directly corroborated the prosecution’s account nor offered support to Escosura’s involvement, with Patapat emphasizing his absence from Sta. Rosa during the incident.
- Juan Barrera testified that he had known the accused since childhood and mentioned his role as a neighborhood association president during the Japanese occupation, with no indication of his involvement in guerrilla activities.
- Angel Tiongco, who served as mayor from December 1944 to February 1945, recounted discussions regarding the potential establishment of a makapili organization in Sta. Rosa, noting that no concrete organization was formed.
- Evidence of Membership in Enemy-Aided Organizations
- The accused was implicated as a makapili and as a member of a semi-military organization known as the "Scout Battalion."
- Evidence, although not fully satisfying the two-witness principle on the makapili charge, was held sufficient by the lower court to establish his adherence to the enemy.
- Testimonies and the accused’s conduct were used to affirm his participation in actions that reflected treasonable intent, particularly in aiding the enemy through arrests and the subsequent events described.
Issues:
- Credibility of the Prosecution’s Witnesses
- Whether the inconsistencies and discrepancies in the testimonies regarding timing, group composition, and sequence of events—stemming from the confusion, excitement, and long time lapse—undermine the overall credibility of the witnesses.
- The extent to which these contradictions affect the veracity of the accounts portraying the accused’s direct participation in enemy-related activities.
- Applicability and Sufficiency of the Two-Witness Rule
- Whether the two-witness requirement, as provided under the law for proving overt acts in treason charges, must strictly apply to all elements of the accused’s actions.
- The adequacy of the evidence regarding the accused’s membership in the makapili or scout battalion, especially when such evidence does not fully conform to the two-witness standard on certain charges.
- Establishment of Treasonable Intent and Adherence to Enemy
- Whether the totality of evidence, including oral testimonies and the accused’s conduct, sufficiently proves his adherence to the enemy and his active participation in treasonous acts.
- The legal implications of differentiating between overt acts requiring explicit proof by two witnesses and the demonstration of a psychological attitude through participation in enemy-aided organizations.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)