Title
Amending Article 114 on Treason Penalties
Law
Executive Order No. 44
Decision Date
May 31, 1945
Sergio Osmeña's Executive Order No. 44 amends Article 114 of the Revised Penal Code to include resident aliens in the definition and punishment of treason, ensuring that both Filipinos and foreigners can be prosecuted for acts against the state during a time of national emergency.

Legal basis and declared intent

  • Executive Order No. 44 is issued under powers vested by the Constitution and laws of the Philippines.
  • The issuance cites Commonwealth Act No. 600, as amended by Commonwealth Act No. 620, and Commonwealth Act No. 671.
  • The governing intent is to safeguard the integrity of the Philippines and preserve internal security during a national emergency.
  • The order aims to curb and suppress treason committed both by Filipinos and by aliens residing in the Philippines.
  • The order is designed to enable the Commonwealth Government to prosecute resident aliens for treason by extending to them the full force and effect of the law.

Amended Article 114: treason definition

  • Article 114 (as amended by Executive Order No. 44) defines treason for a covered person as a person who, owing allegiance to the United States or the Government of the Philippine Islands, is not being a foreigner.
  • The same definition covers conduct where the person levies war against those governments.
  • The definition also covers conduct where the person adheres to their enemies.
  • Treason is committed when adhesion gives aid or comfort to the enemies within the Philippine Islands or elsewhere.
  • The amended structure requires conviction for treason to satisfy the evidentiary rule stated in Article 114.

Penalties for treason: persons owing allegiance

  • Article 114 imposes reclusion temporal to death for the treason described in its first paragraph (for the person not being a foreigner).
  • Article 114 also requires a fine not to exceed 20,000 pesos for that same first-paragraph treason.
  • Article 114 further provides that conviction is governed by the evidentiary requirement on two witnesses or confession in open court.

Penalties for treason: resident aliens

  • Article 114 provides that any alien, residing in the Philippine Islands, who commits acts of treason as defined in the first paragraph is punished under the second paragraph.
  • The penalty for such a resident alien is prision mayor to death.
  • Article 114 also requires a fine not to exceed 20,000 pesos for the resident alien under the second paragraph.

Evidentiary rule for treason conviction

  • Article 114 bars conviction of treason unless supported by at least two witnesses.
  • The two witnesses must testify to the same overt act.
  • Article 114 allows conviction when the accused makes a confession in open court.
  • Article 114 makes the evidentiary requirement a condition of conviction for treason generally, including the amended coverage.

Effect of the amendment

  • Executive Order No. 44 amends Article 114 by substituting the amended treason provisions that now include a penalty scheme for resident aliens.
  • The amendment is expressly framed to alter and modify the prior Article 114 that previously excluded resident aliens.
  • The amended Article 114 contains two penalty tiers: one for persons not being a foreigner and another for resident aliens.

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