THE PEOPLE OF THE PHILIPPINES, PLAINTIFF AND APPELLEE, VS.FRANCISCO M.

ABAD (ALIAS PAQUITO),

DEFENDANT AND APPELLANT.[ G.R. No. L-430, July 30, 1947 ]78 Phil. 766

Facts:

Francisco Abad was found guilty on three counts of the complex crime of treason with homicide. The information
charged appellant of the crime of treason by giving aid and comfort to the Empire of Japan and the Japanese Imperial Forces.
The first question raised by appellant is that the lower court erred in finding the accused guilty on the first count, notwithstanding
the fact that only one witness testified to the overt act alleged therein.

Issue:

Is the appellant correct?

Decision:

Yes. The two-witness rule must be adhered to as to each and every one of all the external manifestations of the overt
act in issue. Although both overt acts are inter-related, it would be too much to strain the imagination if they should be identified
as a single act or even as different manifestations, phases, or stages of the same overt act. Although both acts may logically be
presumed to have answered the same purpose, the singleness of purpose is not enough to make one of two acts.

PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS.EMILIANO CATANTAN Y TAYONG, ACCUSED-APPELLANT.

[ G.R. No. 118075, September 05, 1997 ] 344 Phil. 315

Facts:

Catantan was found guilty with violation of Presidential Decree No. 532 otherwise known as the Anti-Piracy and
Highway Robbery Law of 1974. He contends that the trial court erred in convicting him of piracy as the facts proved only
constitute grave coercion. He further argues that in order that piracy may be committed it is essential that there be an attack on
or seizure of a vessel.

Issue:

Is the contention of Catantan correct?

Decision:

No. Under the definition of piracy in PD No. 532 as well as grave coercion as penalized in Art. 286 of the Revised
Penal Code, this case falls squarely within the purview of piracy. While it may be true that victims were compelled to go
elsewhere other than their place of destination, such compulsion was obviously part of the act of seizing their boat. The
testimony of one of the victims shows that the appellant actually seized the vessel through force and intimidation.