Case Summary (G.R. No. L-406)
Factual Background
On September 21, 1944, at approximately 4 PM, Bienvenido Garcia, accompanied by three armed Japanese soldiers, went to the residence of Carlos Escudero, a known guerrilla operative, and arrested him after ransacking the house. Escudero was subsequently tied up and taken away; he has not been seen since. Testimonies from Carlos Escudero's family members confirmed these details. The following day, Danilo Tagle was apprehended near the pagoda of Ocampo at the Raon Bridge by Garcia and the Japanese soldiers under the pretext that Tagle had attempted to shoot a Japanese sentry. Tagle was confined for 26 days before his release, corroborated by the witness Rodolfo Lopez.
On October 29, 1944, Garcia, along with three Japanese soldiers, arrested Mario Martinez at his home after confiscating a revolver from him. Mistaken for an American due to his appearance, Martinez was taken away alongside his brother Fernando. While Fernando was released shortly after, Mario vanished, never to be seen again. Multiple witnesses, including family members of the victims, testified to these arrests and the role that Garcia played.
Evidence and Testimonies
Several witnesses corroborated the prosecution's version of events, stating that Garcia was acting as a spy for the Japanese military police and even encouraged others to enlist. Garcia, however, denied all allegations and claimed he was called by Escudero's family to prevent his arrest. He further contended that he was merely present to identify Tagle after his arrest and denied involvement in Martinez's apprehension.
Despite his assertion of being forced into service by the Japanese due to torture and his claims of loyalty to the guerrillas, Garcia's testimony lacked credibility. He had previously acknowledged his affiliation with the Japanese forces, suggesting that he had the capacity to influence their decisions regarding arrests, which does not exonerate him from liability for aiding in the treasonous acts.
Legal Analysis
The essence of the legal determination lies in the charge of treason as defined under Article 114 of the Revised Penal Code. Treason is characterized by acts that provide aid and comfort to the enemy, particularly through direct involvement in actions against one’s country or compatriots. In this case, the evidence overwhelmingly reflects that Garcia actively participated in the arrests of individuals who were either guerrillas or suspected to be resistors against the Japanese occupation.
The prosecution presented credible witnesses with no apparent motive to fabricate their testimonies against Garcia. The claims by Garcia regarding a supposed vendetta from one witness were found to be unsubstantiated and implausible. Furthermore, Garcia's assertion
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Case Citation
- Jurisprudence: 82 Phil. 496
- G.R. No. L-406
- Date of Decision: January 07, 1949
Parties Involved
- Plaintiff-Appellee: The People of the Philippines
- Defendant-Appellant: Bienvenido Garcia (Alias Domingo Garcia)
Procedural History
- This case involves the appeal of Bienvenido Garcia against a decision sentencing him for acts constituting treason.
Facts of the Case
- On September 21, 1944, at approximately 4:00 PM, Bienvenido Garcia, accompanied by three armed Japanese soldiers, arrested Carlos Escudero, a guerrilla, at his residence in Manila.
- The house was ransacked, and after tying Escudero, he was taken away and has never been seen since.
- On September 22, 1944, Danilo Tagle was also apprehended by Garcia and the Japanese soldiers near the pagoda of Ocampo at the foot of the Raon bridge. Tagle was detained for 26 days.
- On October 29, 1944, Garcia, again accompanied by three Japanese soldiers, arrested Mario Martinez, a guerrilla, under the mistaken belief that he was an American due to his appearance. Martinez was never seen again after his arrest.
- Witnesses including Leonora Escudero, Filomena Sanchez, Aurelia Escudero, Rodolfo Lopez