TITLE:People v.

Carlos
G.R. NO. L-239 DATE: June 30,1947
PONENTE: NATURE:
FACTS:
● The appellant Apolonio Carlos was found guilty of treason by the People’s Court, sentenced to reclusion perpetua
(lifetime/permanent imprisonment) and to pay a fine of P 7000.
● The lower court was able to find one day of July or August 1944 at around 2 or 3 in the morning a truck pulled up in
front of a house in Constancia St., Sampaloc Manila where a certain Martin Mateo lived. Carlos together with
Japanese military alighted together broke into Martin Mateo’s house then later to Fermin Javier’s house. Martin
mateo, Ladislao Mateo and Fermin Javier were captured by biding hands, they were put inside the truck and were
brought to Fort Santiago, tortured and released after 6 days. Reason: they refused to talk about the whereabouts of
Marcelino Mateo, a guerrilla that was able to escape the Japanese Fermin Javier on the other hand was also arrested
because he was a suspected/ confirmed by Carlos as a guerrilla.
● CONTENTION OF THE ACCUSED: MERE QUESTION OF THE LAW. -
Regarding the fourth assignment of error, appellant advances the following proposition: "The People's Court Law
(Commonwealth Act No. 682) is unconstitutional and void in many parts and as a whole because:

● Why PEOPLE’S COURT ACT (PCA) is unconstitutional: 4 errors 1. The lower Court cannot convicted of treason
because there is a settled principle in international law when a territory is under the governance of an enemy, all
political laws of the previous government are suspended. Thus our laws at that time have no binding effect because
crime of treason is a political complexion. Likewise Philippine laws are inconsistent and suspended, without force
and effect. Allegiance (legal obligation) distinguishable from loyalty. Thus, decision should be reversed because the
law that created it is unconstitutional. -law created PCA is non-binding Japanese law is in force, therefore making it
unconstitutional -PCA contains provisions entirely foreign to the subject matter -Second provision: retaining the
jurisdiction of the Court of First Instance (it should try and decide cases against threats to national security)
● Section 14: Disqualification of SC Justices and procedure of their substitution 1. PCA deprives persons similarly
situated of equal protection of the laws 2. Political offenders accused by PC are denied of preliminary investigation
while others are entitled to. 3. PO accused by PC have a limited right to appeal while the accused charged by courts
of first instance have an absolute right to appeal. 4. Appeals involving person who held public office under Phil.
Exec. Comm and Phil. Rep or any branch are to be heard and decided by a substantially different SC thus lacking
uniformity in rulings over the same subject matter. 5. provision change the existing rules of Court on the subject of
bail 6. Art 125 of RPC: Delay in the delivery of detained persons to the proper judicial authority (shall be allowed
upon request to communicate confer any time with his attorney or counsel)
ISSUE/S:
W/N Crime of treason should be reversed because PCA is unconstitutional.
DOCTRINES | HELD:

RULING:
DECISION: SC AFFIRMED DECISION OF THE LOWER COURT

CONTENTION OF THE STATE: 1. PC is a special court with restricted jurisdiction created under the stress of an
emergency and national security, operate on limited period only imposed by economic necessity and other factors of public
policy. Main concern is the trial and disposition of the cases over 6000 held by US military to be turned over to
Commonwealth government. 2. In view of the great numbers of offenders with limited time, amount of labor will take time if
all of which are allowed to have P.I considering there’s an urgency in disposing the cases. P.I is n9t a fundamental right
guaranteed by the Constitution. 3. PC is a collegiate court while CFI is of single judge. Appeal is not constitutional but a
statutory right. Admitted fact already saves court the provision of being objected from being unconstitutional. 4. No merit on
contention since it is beyond the subject of constitutional guarantee.

The disqualification of some or majority of SC to the PC and their substitution by people from CA, not a new court in the
eyes of the law. -A court possesses a separate personality from the men who compose them -lack of uniformity: constitution
1
does not ensure uniformity of judicial decisions neither does it assure immunity from judicial error. 5. granting bail to
political offenders detained by US army and released to the commonwealth but not to other political offenders 6. suspended
to those political detainees
CRIME: treason Any person who, owing allegiance to (the United States or) the Government of the Philippine Islands, not
being a foreigner, levies war against them or adheres to their enemies, giving them aid or comfort within the Philippine
Islands or elsewhere, shall be punished by reclusion temporal to death and shall pay a fine not to exceed P20,000 pesos.

RECLUSION TEMPORAL: Max- 17 yrs, 4 mos and 1 day to 20 years Medium: 14 yrs, 8 mos and 1 day to 17 years and 4
months Minimum: 12 yrs, 1 day to 14 yrs and 8 months
NOTES:
WISDOM OF LAW A LEGISLATIVE CONCERN.
These objections go to the wisdom of the law and to matters of policy. This being so, it is enough that the Congress
deemed it necessary to incorporate these provisions in Commonwealth Act No. 682. It is not the province of the courts to
supervise legislation and keep it within the bounds of propriety and common sense. That is primarily and exclusively a
legislative concern. (Rubi vs. Provincial Board of Mindoro, 39 Phil., 661.)
CONSTITUTIONAL PROVISION REGARDING UNIFORMITY OF RULES OF COURT, SCOPE OF. — It is
the rules promulgated by the Supreme Court which are required by section 13 of Article VIII of the Constitution to be
uniform for all courts of the same grade. The People's Court is not a court of the same grade, considering many of its
special features, and its purposes, as the Court of First Instance or any other existing court in the Philippines, 80 that the
adoption of special rules of procedure for said court different from those applicable to Courts of First Instance is not
violative of this constitutional mandate. More than this, the last sentence of the section expressly authorizes the Congress
"to repeal, alter, or supplement the rules concerning pleading, practice, and procedure, and the admission to the practice of
law in the Philippines."