Title
People vs. Escosura
Case
G.R. No. L-1291
Decision Date
Nov 2, 1948
Eugenio Escosura, accused of aiding Japanese forces during WWII, was convicted of treason for participating in arrests and a raid leading to a guerrilla leader's death. Witness testimonies and overt acts proved his adherence to the enemy.

Case Summary (G.R. No. L-15544)

Charges and Sentencing

Eugenio Escosura was found guilty on counts one and two of treason and sentenced to reclusion perpetua, a fine of P10,000, and the costs. The convictions were based on testimony regarding Escosura's involvement in arresting local guerrilla fighters and conspiring with Japanese forces, which constituted an adherence to the enemy as defined under Philippine law.

Testimonies Supporting Prosecution

On count one, Jose de Castro, a municipal policeman, testified that Escosura participated in the arrest of police officers during a Japanese raid on October 8, 1943, identifying him as one of several Filipinos cooperating with Japanese soldiers. De Castro described Escosura carrying a rifle and being involved in acts of intimidation against local guerrillas. Similarly, Adolfo Bascon corroborated this account by mentioning that he had seen Escosura in the presence of Japanese forces on numerous occasions.

In count two, Candelaria M. Santos recounted the arrest of her husband, Major Leopoldo Santos, by Japanese troops and collaborating Filipinos, including Escosura on November 16, 1944. She described the traumatic events leading to her husband’s fatal injuries and suggested that Escosura played a prominent role in the armed assault. Additional testimony from Pablo Alumno supported this by recounting the events leading to Major Santos' capture, further implicating Escosura as an active participant in the treacherous collaboration.

Defense and Contradictions

In contrast, the defense called several witnesses, including Valentin de los Reyes and Antonio Patapat, who provided alibis and denied Escosura's involvement in the activities described by the prosecution. However, these testimonies did not successfully undermine the consistency of the prosecution's accounts, as the contradictions noted were deemed not sufficient to discredit the overall credibility of the primary witnesses.

Legal Principles and Evaluation

The ruling hinged on the interpretation of "adherence to the enemy" as established in Article 114 of the Revised Penal Code, which requires at least two witnesses to substantiate claims of overt acts. The trial court found that while some charges did not meet the two-witness requirement, the nature of Escosura's actions demonstrated a profound complicity in treasonous activities, satisfied by the testimonies presented.

Affirmation of Judgment

The appellate court affirmed the judgment of the People’s Court, ruling that the acts of Escosura undeniably in

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