People vs. Cayetano Mangahas and Mariano de los Santos Mangahas

Facts:

The respondents in the criminal information were Cayetano Mangahas and Mariano de los Santos Mangahas (defendants and appellants). They were charged with treason in Cases Nos. 742 and 744 of the Court of First Instance of Bulacan and, with their consent, tried jointly. After trial the trial court found both guilty as charged and sentenced each to 14 years, 8 months and 1 day of reclusion temporal, the accessory penalties of law, a fine of P10,000, and costs. Both appealed to the Supreme Court.

The prosecution's evidence described several incidents during December 1944 in Norzagaray, Bulacan. On 13 December 1944, at about 11 a.m., guerrilla runner José Pérez informed guerrilla commander Martin de la Merced that about 30 armed Makapilis had raided Lawang and apprehended guerrillas. Martin and other guerrillas fled; subsequent runners informed Martin’s wife, Enriqueta B. de la Merced, that the Makapilis were in front of the municipal building. Enriqueta and another witness, Engracia de la Cruz, testified that Makapilis — among whom they identified Cayetano, Mariano and Francisco Castillo — surrounded and entered the house and took food supplies intended for the guerrillas (five sacks of rice, canned beef, baskets of produce, salt and a half-sack of canned goods) to the Makapili garrison.

On 30 December 1944 five persons, including the two appellants, allegedly apprehended Moises Legaspi at his home and took him to the Makapili garrison; Legaspi was not seen thereafter. His wife, Purita Ramos, and their son Matias Legaspi (who was 11 at the time of the arrest and 16 when he testified) identified the appellants among the captors and so testified at trial.

Separate incidents included, on 29 December 1944, the alleged seizure of goods and the apprehension of Primo S. Cruz, who was brought to the San Jose garrison where Japanese soldiers were stationed and subsequently disappeared; the only testimony as to this arrest came from his widow Maria S. Cruz. On 30 December 1944 Artemio Nicolas was likewise seized and conveyed to the garrison and later disappeared; his widow Virginia Boluran was the only witness to that arrest. The defendants admitted Filipino citizenship.

At trial the prosecution relied on eyewitness identifications, the defendants’ activities (arresting guerrillas, commandeering food, performing sentry duty, drilling publicly and carrying firearms), and their prior membership in the Ganap Party and later affiliation with the Makapili to establish adherence to the enemy. The defense offered denials and an alibi: Cayetano claimed he and his brother were arrested by the Japanese on 25 December 1944 and thus could not ...(Pro-only)

Issues:

• Was the evidence sufficient to sustain the appellants’ convictions for treason?
• Do the arrests of Primo S. Cruz and Artemio Nicolas, as proved only by their widows, amount to treason despite lack of two witnesses?
• Does Cayetano Mangahas’s uncorroborated assertion that he was arrested by the Japanese on 25 December 1944 negate the eyewitness identifications placi...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

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Doctrine:

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