Case Digest (G.R. No. 199420) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippines versus Carmelito Victoria, decided on March 13, 1947, before the Supreme Court sitting en banc, the defendant-appellant, Carmelito Victoria alias Carlito Victoria, a Filipino citizen owing allegiance to the United States and the Commonwealth of the Philippines, was charged with treason under Article 114 of the Revised Penal Code. The information alleged that between March 1942 and December 1944, in Lucena, Tayabas, San Pablo, Laguna, Pasay, Rizal, and other locations within the court’s jurisdiction, Victoria knowingly adhered to the Empire of Japan, then at war with the Philippines, by joining Japanese military patrols, participating in raids, arrests, torture, theft, arson, and concealment of guerrilla suspects. Seven overt acts were detailed, including the bayonet murder of Federico Unson Jr. and Isaias Perez, the disappearance of Ruben Godoy and Jose Unson, and the torture of Hermogenes Caluag and Melecio Labalan. At the trial in the People’s Case Digest (G.R. No. 199420) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- Plaintiff: People of the Philippines; Defendant: Carmelito Victoria, charged with treason under Article 114, Revised Penal Code.
- Period: March 1942 to December 1944, during Japanese occupation of the Philippines.
- Overt Acts Alleged (Seven Counts)
- Count 1 (Oct. 6, 1944): As member of Kempei Tai intelligence, joined patrol raiding Federico Unson’s house in Lucena, Tayabas; participated in two arrests; victims Federico Unson and Isaias Perez tortured and killed; Ruben Godoy taken to garrison and killed.
- Count 2 (Dec. 21, 1944): Raid on Jose Unson’s house; arrest and transfer to Japanese garrison; disappearance; skull later exhumed in Lukban.
- Count 3 (Feb. 10, 1945): Raid on Felixberto Romulo’s house in San Pablo, Laguna; arrest as guerrilla suspect; disappearance thereafter.
- Count 4 (Dec. 21, 1944, 5 a.m.): Raid on Hermogenes Caluag’s house in Lucena; arrest and torture at Japanese garrison.
- Count 5 (Mar. 9, 1944): As informer, caused arrest of guerrilla officer Antonio San Agustin in Pasay; detention until Sept. 20, 1944.
- Count 6 (June 1944): Raid on Melecio Labalan Sr.’s house; arrest and torture at Lucena garrison.
- Count 7 (Feb. 1945): Membership in Makapili; took arms and training; participated in raids, barrio burning, supply and sentry duties for Japanese Army.
- Proceedings Below
- Lower People’s Court found counts 1, 2, 3, 4, and 6 proven; counts 5 and 7 not proven; sentenced Victoria to death, a ₱20,000 fine, and costs.
- Appellant testified to coercion, alibi, humanitarian acts, and assistance to guerrillas as defenses.
Issues:
- Whether the appellant’s overt acts constitute treason under Article 114, RPC.
- Whether the lower court’s factual findings are supported by evidence.
- Whether appellant’s defenses (alibi, coercion, humanitarian acts) mitigate or exempt criminal liability.
- Proper penalty—death or reclusion perpetua—in light of alleged aggravating circumstances and requirement of unanimity.
- Whether the People’s Court had jurisdiction to try the case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)