Case Digest (G.R. No. L-5367) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. Nos. L-5367 & L-5368, decided on June 9, 1953, the People of the Philippines charged Cayetano Mangahas and Mariano de los Santos Mangahas, Filipino citizens, with treason (Court of First Instance of Bulacan, Cases Nos. 742 and 744). By their consent, both were tried jointly and convicted of adherence to the enemy through overt acts, sentenced to 14 years, 8 months, and 1 day of reclusion temporal, the accessory penalties, a fine of ₱10,000 each, and costs. On December 13, 1944, about thirty armed Makapilis—including the appellants—raided the house of guerrilla commander Martin de la Merced in Lawang, Norzagaray, seizing foodstuffs destined for guerrilla forces. On December 29 and 30, groups of Makapilis, again with the two Mangahas brothers, forcibly took Primo S. Cruz and Artemio Nicolas from their homes to the San Jose garrison, where both disappeared, presumed executed. Also on December 30, the defendants, among five Makapilis, arrested guerrilla member Moises Legaspi Case Digest (G.R. No. L-5367) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- Cayetano Mangahas and Mariano de los Santos Mangahas were jointly charged with treason (Court of First Instance of Bulacan, Cases Nos. 742 and 744).
- After trial, both were convicted and sentenced to 14 years, 8 months, and 1 day of reclusión temporal, the accessory penalties, each to pay a ₱10,000 fine and costs.
- Both defendants appealed the conviction to the Supreme Court.
- Overt Acts and Evidence
- December 13, 1944 raid
- José Perez, Julian Payumo, and Lucio Ocampo alerted guerrilla commander Martin de la Merced and his wife, Enriqueta, of a 30-man Makapili raid at Lawang, Norzagaray.
- Makapilis—including the appellants—surrounded and entered the Merced house, seizing five sacks of rice, canned beef, camote, tomatoes, salt, sardines, salmon, and corned beef.
- Testimony by Enriqueta B. de la Merced and Engracia de la Cruz placed the appellants among the raiders.
- December 30, 1944 arrest of Moisés Legaspi
- Five Makapilis, including both appellants, arrested Legaspi at his Norzagaray home and brought him to the garrison; he was never seen again.
- Purita Ramos and her son Matías (then 11) identified the appellants as among the arresting parties.
- December 29–30, 1944 abductions of Cruz and Nicolás
- Primo S. Cruz was seized from his house; possessions were taken; he was brought to the San José garrison and disappeared.
- Artemio Nicolás underwent a similar fate; both disappearances were testified to only by their widows (one witness each).
- Allegations of adherence to the enemy
- Defendants admitted Filipino citizenship.
- They performed sentry duties, drills in the public plaza, and supply seizures as Makapili members.
- They were former Ganap Party members and actively collaborated during Japanese occupation.
- Defendants’ denials
- Cayetano Mangahas claimed he and his brother were arrested by the Japanese on December 25, 1944, and thus could not have participated in the December 13 raid.
- The trial court found this uncorroborated and credited the eyewitnesses.
Issues:
- Whether the evidence is sufficient to prove treason, given the lack of two witnesses for certain overt acts.
- Whether the appellants’ denial of participation and claim of their own Japanese arrest undermines the prosecution’s eyewitness testimony and belief in their adherence to the enemy.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)