Case Summary (G.R. No. L-2997)
Summary of Charges and Evidence
The information against San Juan included eleven counts of treason; however, his conviction was based solely on counts 1, 2, 8, and 10. Count 1 revolved around events that occurred in December 1943, during a period described as an amnesty. The prosecution's evidence indicated that a group of individuals, including Vivencio Panganiban and Rustico Cabasco, met to discuss guerrilla activities. Upon learning that the Japanese were approaching, San Juan went to a Japanese garrison and returned with four armed Japanese soldiers. He later attacked guerrillas, resulting in their flight.
Testimony and Evidence Evaluation
Witnesses Gerundio Villanisa and Rustico Cabasco provided testimony that supported the prosecution's claim. There was a noted discrepancy between their accounts, with Villanisa stating that San Juan went directly to the Japanese garrison, while Cabasco only mentioned seeing San Juan with the Japanese without detailing his trip to the garrison. However, this discrepancy was characterized as more apparent than real, as both testimonies collectively established that San Juan collaborated with the Japanese forces against local guerrillas.
Application of the Two-Witness Rule
The appellate counsel argued that counts 2, 8, and 10 lacked sufficient corroboration, adhering to the two-witness rule required in treason cases. Nevertheless, the court found count 1 alone sufficient to affirm San Juan's conviction. His actions showed implied adherence to the enemy, notably through his armed collaboration and acknowledgment of leaving Lopez with the Japanese troops.
Sentencing and Legal Conformity
The penalty of reclusion perpetua was deemed appropriate by the trial court, as the circumstances of the case presented neither mitigating nor aggravating factors. The Constitutional frame
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Case Overview
- This case involves an appeal from Lamberto San Juan, found guilty of treason by the Court of First Instance of Quezon.
- The judgment sentenced him to reclusion perpetua, a fine of fifteen thousand pesos, and the costs of the case.
- The information against him included eleven counts, but his conviction was based solely on counts 1, 2, 8, and 10.
Background of the Case
- The appellant, Lamberto San Juan, is identified as a Filipino citizen.
- The events leading to the charges occurred in December 1943 during the Japanese occupation of the Philippines.
- A group meeting took place in the house of Potenciano Desembrana to discuss guerrilla matters when they received news about the approaching Japanese forces.
Key Events Leading to Charges
- During the meeting, the group began to disperse upon hearing the news of the Japanese arrival.
- San Juan encountered Gerundio Villanisa, who revealed he was conversing with guerrillas.
- San Juan then proceeded to the nearby Japanese garrison and returned with four armed Japanese soldiers.
- The appellant and the Japanese soldiers