Case Summary (G.R. No. L-980)
Facts and Charges
The original information, filed on March 6, 1946, charged Guinto with treason for acting as a spy and informer for the Japanese Military Police, helping in the capture and subsequent deaths or disappearances of guerrillas and pro-American elements in Manila during the Japanese occupation. Specifically, it alleged that Guinto arrested Ernesto Simpao, a guerrilla, who was then executed by the Japanese. On May 25, 1945, prior to Guinto’s plea, an amended information was filed, specifying additional overt acts of treason involving the arrest and disappearance of several other guerrillas, including Albino Rutao, Ariston Tamon and an accomplice, and Felix de Leon.
Legal Issue Presented
The central issue was whether the filing of an amended information after the initial information—alleging new overt acts of treason but not charging a distinct new offense—was permissible under Commonwealth Act No. 682. The petitioner argued that the amendment, which introduced additional overt acts, was effectively a new charge filed after the prescribed six-month period following the Act's passage, thus depriving the People’s Court of jurisdiction to entertain them.
Relevant Statutory Provisions
Commonwealth Act No. 682, Section 2, grants the People’s Court jurisdiction over crimes against national security committed between December 8, 1941, and September 2, 1945, only if cases are filed within six months from the passage of the Act; otherwise, jurisdiction lies with the regular Courts of First Instance. Section 22 of the Act mandates that proceedings shall be governed by existing laws and the Rules of Court unless otherwise specified.
Rule 106, Section 13 of the Rules of Court allows the amendment of an information in substance or form without leave of court at any time before the defendant pleads.
Court’s Analysis on the Amended Information
The Supreme Court held that the amended information did not constitute a new criminal charge but merely specified additional overt acts to better particularize the original charge of treason. Because treason is a continuous offense that may be committed through several overt acts, all acts supporting the singular crime constitute one offense. The amendment thus related back to the date of filing the original information, which was within the six-month jurisdictional period.
Legal Principles on Overt Acts and Treason
The decision emphasized that proof of treason requires specific overt acts to be alleged and proven, as general allegations of giving aid and comfort to the enemy are insufficient. The defendant must be informed not only of the offense but also the particular acts constituting it to guarantee due process, as mandated by Section 1 (b), Rule 111 of the Rules of Court.
Procedural Due Process and Jurisdiction
Allowing amendment to specify additional overt acts before plea under Rule 106, Section 13 conformed to procedural rules. Since the amendment was made before Guinto’s plea, it was proper and did not violate the jurisdictional time limit under Commonwealth Act No. 682.
The Court reasoned that rejecting
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Factual Background
- The petitioner, Jose Guinto, was charged with treason by an original information filed on March 6, 1946, in the People’s Court.
- The charge alleged that as a Filipino citizen owing allegiance to the United States and the Commonwealth of the Philippines, Guinto violated this duty between November 1, 1944, and February 3, 1946, in Manila.
- Specifically, he was accused of acting as a spy and informer for the Japanese Military Police, assisting them in apprehending guerrillas and pro-American elements.
- An overt act included arresting Ernesto Simpao, a guerrilla, tying his hands, forcing him into Manila North Harbor water, where Simpao was subsequently shot to death.
- On May 25, 1945, the Office of the Official Prosecutors filed an amended information as a bill of particulars, adding specific overt acts:
- Helping five armed Japanese spies arrest Albino Rutao, a guerrilla suspect, who disappeared after arrest.
- Leading six armed Filipino spies to arrest Ariston Tamon and an unknown guerrilla companion, who were punished and never seen again.
- Guiding three armed Japanese spies to arrest Felix de Leon, a guerrilla, taken to a military garrison and never seen after.
Procedural Posture
- The petitioner’s attorneys moved to quash the three additional overt acts alleged in the amended information, arguing the amendment was an impermissible new filing after a six-month statutory deadline had elapsed.
- The People’s Court denied the motion to quash and a subsequent motion for reconsideration.
- The petitioner then filed a petition for certiorari, challenging the People’s Court’s jurisdiction in admitting the amended information.
Statutory and Legal Framework
- Section 2 of Commonwealth Act No. 682 grants the People’s Court