G.R. No. L-365 - People vs. Racaza

Antonio Racaza, a Filipino citizen loyal to the United States and the Commonwealth of the Philippines, was charged with 14 counts of treason committed between January 1944 and February 1945 in various municipalities within Cebu and Bohol.
The charges stemmed from his wilful and treasonable adherence to the Empire of Japan during World War II, by aiding Japanese forces in the Philippines in multiple felonious acts.
Racaza acted as a Japanese spy and collaborator who actively led, guided, and accompanied Japanese soldiers and Filipino covert operatives in arresting, torturing, and killing suspected guerrillas and their sympathizers.

Participating in the arrest and torture of numerous persons suspected of guerrilla activities.
Using violence and intimidation including beatings, choking, and hanging detainees.
Being involved in the Basac massacre where accused instructed and conducted torture and executed at least one victim.
Assisting in efforts to extract intelligence by brutal and cruel means from suspected guerrillas and their families.
Committing acts of sexual violence and intimidation against civilians, notably the undressing and attempted rape of Silvina Cabellon.
Escorting patrols conducting systematic raids, arrests, torture, and killings under Japanese military direction.

Racaza’s trial was held before the First Division of the People’s Court in Cebu City.
The trial was marked by procedural irregularities, inconsistent pleas, and confusion over various counts:

Initially, Racaza’s counsel informed the court the accused wished to plead guilty to all counts for mercy.
Upon reading the information, Racaza admitted guilt only on certain counts and denied or contested others.
During trial, the accused changed pleas multiple times, finally pleading guilty to some counts (2, 3, and 13) and claiming innocence or qualification on others.

The prosecution presented eyewitness testimony substantiating several counts of torture, arrest, and killings.
The accused later admitted to many acts, but claimed some killings and atrocities were committed by Japanese officers or other collaborators and only two or three counts survived with a clear plea of guilty.

Eyewitnesses testified to Racaza’s direct participation in arrests, beatings, torture, executions, and other inhumane acts under Japanese command.
Specific victims and incidents were described, including dates, places, nature of torture, and murders witnessed by survivors.
The accused himself admitted presence and partial involvement but sought to limit his responsibility by attributing authority to Japanese officers.
Several victims and witnesses testified to the brutality, including direct accusations that Racaza personally killed some victims and participated in mass tortures such as the Basac massacre.

The trial court found Racaza guilty of all 14 counts and imposed the death penalty, a fine of ₱20,000, and costs.
The decision recognized irregularities but accepted the confessions and corroborative testimonies as proof of guilt.
The court found aggravating circumstances including evident premeditation, superior strength, treachery, and use of means to add ignominy to the offenses, enhancing the gravity of treason.
The decision recognized the harsh and brutal nature of Racaza’s acts but noted some aggravating factors like treachery and superior strength are inherent in treason itself rather than separate aggravations.

The Supreme Court justices reviewed the case and evidence, affirming guilt on counts where confessions and eyewitnesses substantiated the acts.
The majority agreed that Racaza’s involvement justified severe punishment but moderated the death penalty to reclusion perpetua due to dissent by four justices on the imposition of death.
The Court clarified the aggravating factors applicable and stressed the importance of matching penalties with severity and nature of offenses committed in treason cases.
Justice Perfecto concurred with guilt but dissented on the penalty, noting the influence of public indignation (“mob frenzy”) on trial and questioning the appropriateness of the death penalty. He emphasized the plea of guilty as mitigating and rejected the use of the attempted rape as aggravating treason given its non-political nature.
The Court acknowledged the need to differentiate acts politically connected to treason from other crimes like rape.

Whether Antonio Racaza is guilty of treason based on the acts of aiding the enemy and committing violent overt acts during the Japanese occupation.
Whether Racaza’s plea of guilty to certain counts and his inconsistent pleas affect the determination of guilt and penalties for the other counts.
Whether the trial court properly recognized and applied aggravating and mitigating circumstances in imposing the death penalty.
Whether the penalty of death is appropriate and just under the circumstances of this case.
Whether acts such as attempted rape constitute aggravating circumstances in the crime of treason or should be prosecuted separately.