Title
People vs. Victoria
Case
G.R. No. L-369
Decision Date
Mar 13, 1947
Carmelito Victoria, a Filipino, was convicted of treason for aiding Japanese forces during WWII, participating in raids, arrests, torture, and killings. The Supreme Court affirmed his guilt but reduced his death penalty to reclusion perpetua.

Case Summary (G.R. No. L-369)

Petitioner’s Alleged Conduct

Victoria, a Filipino citizen owing allegiance to the United States and the Commonwealth, is charged under Article 114 of the Revised Penal Code with treason for knowingly adhering to the Empire of Japan between March 1942 and February 1945. He is accused of giving aid and comfort to the enemy by:

  1. Participating in armed raids and arrests of suspected guerrillas in Lucena, Tayabas (October 6 and December 21, 1944).
  2. Involvement in the arrest, torture, and presumed killing of Federico Unson, Isaias Perez, Ruben Godoy, and Jose Unson.
  3. Raiding the house of Felixberto Romulo in San Pablo, Laguna, and turning him over to Japanese forces (February 10, 1945).
  4. Assisting in the raid and torture of Hermogenes Caluag in Lucena (December 21, 1944).
  5. Acting as informer leading to the arrest and torture of Antonio San Agustin in Pasay (March 9, 1944); and arresting Melecio Labalan, Sr., in Lucena (June 1944).
  6. Joining the Ganap and Makapili pro-Japanese organizations, bearing arms, performing sentry duty, transporting supplies, and participating in the burning of a barrio in San Pablo (from February 1945 onward).

Key Dates

• March 9, 1944 to February 1945: Overt acts of adherence and assistance to Japanese forces
• Trial Court Judgment: Date not specified (People’s Court conviction)
• Supreme Court Decision: March 13, 1947

Applicable Law

• Constitution: 1935 Philippine Constitution (in force at time of offense)
• Statute: Article 114, Revised Penal Code (treason)
• Aggravating Circumstances Alleged: Treachery; use of armed persons to afford impunity; deliberate augmentation of wrongdoing.

Facts Found by the Lower Court

• Eyewitness testimony established Victoria’s active participation in multiple raids alongside Japanese Kempei Tai or Military Police.
• Victims’ remains (Unson, Perez, Unson Jr.) were found mutilated, disemboweled, or missing after arrests in which Victoria took part.
• Credible witnesses (Mrs. Unson Jr., Dolores Kalakasan, Elena Romulo, Enriqueta Alviar, Mercedes Unson, Alejandro Unson, Eugenio Ramon Unson) uniformly identified Victoria’s presence and role.
• Appellant’s defenses—alibi, coercion, occasional intercession for guerrilla suspects, and claims of pro-guerrilla activities—were rejected as uncorroborated or insufficient to overcome prosecution evidence.

Issues on Appeal

  1. Whether the evidence sustains convictions for overt acts alleged in counts 1, 2, 3, 4, and 6.
  2. Whether the acts constitute treason or ordinary crimes.
  3. Whether aggravating circumstances apply.
  4. Whether the penalty of death is justified.

Supreme Court Holdings

• Evidence Review: No specific factual errors found in the lower court’s determinations; all material elements of overt acts proven beyond reasonable doubt.
• Characterization of Offense: The accused’s coordinated assaults, arrests, torture, and killings at the behest of Japanese forces satisfy the definition of treason under Article 114—adherence to the enemy and giving aid and comfort.
• Aggravating Circumstances: Majority held that treachery, use of armed accomplices, and deliberate aggravation of wrongs qualify as aggravating factors distinct from the essential elements of treason.
• Penalty Determination: Lack of unanimity among Justices on imposition of death. Nine voted to affi



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