Case Digest (A.M. No. P-04-1867) Core Legal Reasoning Model
Facts:
This case involves Marcelo Alatiit as the defendant-appellant and the People of the Philippines as the plaintiff-appellee. The decision was rendered by the Supreme Court of the Philippines on June 29, 1950. Marcelo Alatiit, a Filipino citizen, was charged with treason under four counts and was found guilty on three counts by the People’s Court, which sentenced him to life imprisonment and a fine of ten thousand pesos plus costs. The events leading to Alatiit's conviction took place during the Japanese occupation in World War II, specifically in Binan, Laguna.
Alatiit was identified as a member and captain of the Makapili organization, a military group established by the Japanese to support their war efforts, particularly against the Filipino guerrilla resistance. On June 20, 1943, he participated in an operation with Japanese soldiers to arrest Gregorio Corrales at the residence of Angeles Vicentina. Alatiit directed Corrales to the Japanese soldiers and was involved in th
Case Digest (A.M. No. P-04-1867) Expanded Legal Reasoning Model
Facts:
During the Japanese occupation, a branch of the Makapili organization was active in Binan, Laguna. Marcelo Alatiit, a Filipino citizen and alleged member—and even captain—of the subversive Makapili group, was seen patrolling with armed Japanese soldiers. On June 20, 1943, at about 9:00 p.m., Japanese soldiers accompanied by Filipino collaborators, including Alatiit, went to the residence of Angeles Vicentina in barrio Malaban, Binan, to inquire about the location of Gregorio Corrales. Upon being directed, the group arrested Corrales, and similarly apprehended Macario Alzona and Juan Romero in separate incidents. These individuals, suspected guerrilla sympathizers, were subsequently turned over to Japanese military authorities and confined for several days. Later, in mid-November 1943 at around 2:00 a.m., Japanese soldiers, accompanied by Alatiit and Matias Almazan, raided the house of Felipe Capili in barrio Malaban, resulting in the arrest of Capili, Valentin Belmonte, and Belmonte’s two sons. The captives, whose testimony came from Angeles Vicentina, Valentin Belmonte, and Felipe Capili, confirmed that Alatiit was among those conducting the apprehensions. In contrast, Alatiit denied any connection with the Makapili, contending that he was merely a bystander during the arrests, and even produced witnesses stating there was no Makapili organization in town. However, the trial court found these defenses unmeritorious, relying on the testimony of at least seven witnesses who attested to his active participation while on patrol with armed personnel.Issues:
- Whether the evidence was sufficient to establish that Marcelo Alatiit was an active member of the Makapili organization, particularly in light of his denial and claim of being a mere bystander during the arrests.
- Whether the application of the two-witness rule in cases involving serious offenses such as treason was properly satisfied by the testimonies presented against him.
- Whether the trial court’s findings, which relied on the corroborative evidence provided by both eyewitnesses and the arrested suspects, warrant an affirmation of his conviction for treason on three counts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)