ANASTACIO LAUREL vs.

ERIBERTO MISA
G.R. No. L-409 | January 30, 1947

Facts: A petition for habeas corpus was filed by Anastacio Laurel based on the theory that a
Filipino citizen who adhered to the enemy giving the latter aid and comfort during the Japanese
occupation cannot be prosecuted for the crime of treason defined and penalized by article 114
of the Revised Penal Code. He cited the following reasons: (1) that the sovereignty of the
legitimate government in the Philippines and, consequently, the correlative allegiance of Filipino
citizens thereto was then suspended; and (2) that there was a change of sovereignty over the
Islands upon the proclamation of the Philippine Republic.

Issue: Whether or not Anastacio Laurel can be prosecuted for the crime of treason

Held: Yes. Article 114 of the Revised Penal Code is applicable to treason committed against the
national security of the legitimate government, because the inhabitants of the occupied territory
were still bound by their allegiance to the latter during the enemy occupation. Since the
preservation of the allegiance or the obligation of fidelity and obedience of a citizen or subject to
his government or sovereign does not demand from him a positive action, but only passive
attitude or forbearance from adhering to the enemy by giving the latter aid and comfort, the
occupant has no power, as a corollary of the preceding consideration, to repeal or suspend the
operation of the law of treason.

People of the Philippines vs. Eduardo Prieto

G.R. No. L-399 | January 29, 1948
Tuason, J.

Facts: Appellant Eduardo Prieto was prosecuted for treason on 7 counts. Two witnesses gave
evidence on count 4 but their statements do not coincide on any single detail. Juanito Albaño
testified that the accused walked behind a sled while Valentin Cuison testified that he saw the
accused with the American, Japanese and other Filipinos. On counts 1, 2, 3 and 7, the accused
acting as undercover, lead a patrol of Japanese soldiers and Filipino undercovers in
apprehending guerillas and locating their hideouts. The lower court believed that the accused is
guilty beyond reasonable doubt of the crime of treason complexed by murder and physical
injuries with aggravating circumstances.

Issues:
1) Whether or not the accused is guilty of treason as charged in count 4
2) Whether or not the accused is guilty of the crime of treason complexed by murder and
physical injuries

Held:
1.) No. The evidence does not satisfy the two-witness principle. The two witnesses failed to
corroborate each other not only on the whole overt act but on any part of it. Cuison
 testified that there was no sled, nor did he see Albaño. Hence, the defendant is not guilty
of treason as charged in count 4.
2.) No. The execution of some of the guerrilla suspects and the infliction of physical injuries
on others are not offenses separate from treason. When the deed is charged as an
element of treason, it becomes identified with the latter crime and cannot be the subject
of a separate punishment or used in combination with treason to increase the penalty as
article 48 of the Revised Penal Code provides. Hence, the defendant is guilty only of
treason as charged in counts 1, 2, 3 and 7.

People of the Philippines vs. Jaime Rodriguez, et al.

G.R. No. L-60100 | March 20,1985

Facts: Jaime Rodriguez and the other accused-appellants were crew members of M/V Noria
767, a barter trade vessel of the Philippine registry. They conspired with one another and armed
with bladed weapons and firearms, stole the equipment and other personal properties belonging
to the crew members and passengers of the ship. They also employed physical violence to the
crew and passengers of the vessel. They were found guilty of the crime of piracy and sentenced
to suffer the extreme penalty of death.

Issue: Whether or not the court erred in imposing the penalty of death imposed;

Held: No. Presidential Decree No. 532 amending Article 134 of the Revised Penal Code
provides that if rape, murder or homicide is committed as a result or on the occasion of piracy,
or when the offenders abandoned the victims without means of saving themselves, or when the
seizure is accomplished by firing upon or boarding a vessel, the mandatory penalty of death
shall be imposed. Article 63 of the same Code provides that in all cases in which the law
prescribes a single indivisible penalty, it shall be applied by the courts regardless of any
mitigating or aggravating circumstances that may have attended the commission of the deed.
Hence, penalty was properly imposed.

4. The People of the Philippines vs. Julaide Siyoh, et al.

G.R. No. L-57292 | February 18, 1986
Abad Santos, J.

Facts: Julaide Siyoh, Omarkayam Kiram and their companions were accused of qualified piracy
with triple murder and frustrated murder. The accused, armed with firearms and taking
advantage of their superior strength, fired their guns into the air and stopped the pumpboat
wherein Rodolfo de Castro, Danilo Hiolen, Anastacio de Guzman and Antonio de Guzman were
riding. They boarded said pumpboat and took away all their cash and other personal
belongings. They ordered De Castro and the others to jump into the water and fired upon them.
Only Antonio survived and testified for the prosecution. Only Siyoh and Kiram were
apprehended and were found guilty beyond reasonable doubt of the crime of qualified piracy
with triple murder and frustrated murder.
Issue: Whether or not the accused are guilty of the crime of qualified piracy with triple murder
and frustrated murder

Held: Yes. The trial court which had the opportunity of observing the demeanor of the witnesses
assigned credibility to the former. The death certificates of the victims are consistent with the
testimony of Antonio that they were hacked and that the accused were armed with barongs and
armalites. Moreover, there is no reason to suppose that Anastacio is still alive or that he died in
a manner different from his companions. The number of persons killed on the occasion of piracy
is not material. P.D. No. 532 considers qualified piracy, i.e. rape, murder or homicide is
committed as a result or on the occasion of piracy, as a special complex crime punishable by
death regardless of the number of victims.

5. PEOPLE OF THE PHILIPPINES vs. ROGER P. TULIN ET AL.

G.R. No. 111709 | August 30, 2001
Melo, J.

Facts: M/T Tabangao was suddenly boarded by seven fully armed pirates led by Emilio
Changco, older brother of accused-appellant Cecilio Changco. They took complete control of
the vessel and forced the crew to sail to Singapore while sending misleading radio messages to
PNOC that the ship was undergoing repairs. The vessel’s cargo was transferred to another
vessel Navi Pride which was supervised by Cheong San Hiong. Then, the Chief Engineer,
accompanied by the members of the crew, called the PNOC Shipping and Transport
Corporation office to report the incident and arrests were made. Accused-appellants were
convicted of qualified piracy. Cheong argues that Republic Act No. 7659 in effect obliterated the
crime committed by him.

Issue: Whether or not Republic Act No. 7659 obliterated the crime committed by accused-
appellant Cheong

Held: No. Article 122 of the Revised Penal Code, before its amendment, provided that piracy
must be committed on the high seas by any person not a member of its complement nor a
passenger thereof. Upon its amendment by Republic Act No. 7659, the coverage of the
pertinent provision was widened to include offenses committed "in Philippine waters." On the
other hand, under Presidential Decree No. 532 (issued in 1974), the coverage of the law on
piracy embraces any person including "a passenger or member of the complement of said
vessel in Philippine waters." Hence, passenger or not, a member of the complement or not, any
person is covered by the law. Republic Act No. 7659 neither superseded nor amended the
provisions on piracy under Presidential Decree No. 532. Hence, R.A. No. 7659 did not obliterate
the crime committed by Cheong.
6. IN THE MATTER OF THE PETITION FOR HABEAS CORPUS OF ROBERTO UMIL, ET AL.
vs. FIDEL V. RAMOS, ET AL.
G.R. No. 81567 | July 9, 1990

Facts: These are eight petitions for habeas corpus filed before the Court. Respondents
uniformly assert that the privilege of the writ of habeas corpus is not available to the petitioners
as they have been legally arrested and are detained by virtue of valid informations filed in court
against them. Petitioners counter that their detention is unlawful as their arrests were made
without warrant and that no preliminary investigation was first conducted, so that the
informations filed against them are null and void. The cases herein involve affiliation with the
New People’s Army, illegal possession of firearms and ammunition, killing, and inciting to
sedition.

Issue: Whether or not the persons detained have been arbitrarily deprived of their constitutional
right to liberty

Held: No. An arrest without a warrant of arrest under Section 5 paragraphs (a) and (b) of Rule
113 of the Rules of Court, as amended, is justified when the person arrested is caught in
flagrante delicto, viz., in the act of committing an offense; or when an offense has just been
committed and the person making the arrest has personal knowledge of the facts indicating that
the person arrested has committed it. The record of the instant cases would show that the
persons in whose behalf these petitions for habeas corpus have been filed, had freshly
committed or were actually committing an offense, when apprehended, so that their arrests
without a warrant were clearly justified, and that they are, further, detained by virtue of valid
informations filed against them in court.

7. People of the Philippines vs. Ruben Burgos y Tito

G.R. No. L-68955 | September 4, 1986
Gutierrez, Jr., J.

Facts: By virtue of an intelligent information obtained by the Constabulary and INP units from
one Cesar Masamlok who stated that he was forcibly recruited by accused Ruben Burgos as
member of the NPA, a joint team of PC-INP units arrested Ruben who was then plowing his
field. Upon questioning the accused’s wife about Ruben’s firearm, the wife pointed to a place
below their house where a gun was buried in the ground. Ruben was then convicted of the
crime of Illegal Possession of Firearms in Furtherance of Subversion. In his defense, Ruben
averred that he was investigated by soldiers in the PC barracks where he was detained with
respect to the subject firearm and tortured to admit ownership of the firearm.

Issue: Whether or not the arrest of Ruben without a valid warrant is lawful

Held: No. Under Section 6(a) of Rule 113, the officer arresting a person who has just
committed, is committing, or is about to commit an offense must have personal knowledge of
that fact. The offense must also be committed in his presence or within his view. In this case,
whatever knowledge was possessed by the arresting officers, it came in its entirety from the
information furnished by Cesar Masamlok. The location of the firearm was given by the
appellant’s wife. At the time of the appellant’s arrest, he was not in actual possession of any
firearm or subversive document. Neither was he committing any act which could be described
as subversive. He was, in fact, plowing his field at the time of the arrest. Hence, the arrest is not
lawful.

8. Ramon S. Milo and Armando Valdez vs. Angelito C. Salanga and Juan Tuvera, Sr.
G.R. No. L-37007 | July 20,1987

Facts: Accused barrio captain Juan Tuvera Sr. together with private individuals allegedly
maltreated Armando Valdez by fistblows and by hitting him with the butts of their guns. Tuvera
with members of the police force, without legal grounds, detained Valdez inside the municipal
jail for about 11 hours. They were charged with Arbitrary Detention under Art. 124 of the RPC.
Tuvera filed a motion to quash the information on the ground that the facts charged do not
constitute an offense, and that the proofs adduced at the investigation are not sufficient.
Assistant Provincial Fiscal Ramon S. Milo filed an opposition. Respondent Judge Salanga
granted the motion to quash, averring that Tuvera was not a public officer who can be charged
with Arbitrary Detention.

Issue: Whether or not a barrio captain is a public officer who can be charged with Arbitrary
Detention

Held: Yes. Long before Presidential Decree 299 was signed into law, barrio lieutenants were
recognized as persons in authority. The public officers liable for Arbitrary Detention must be
vested with authority to detain or order the detention of persons accused of a crime. One need
not be a police officer to be chargeable with Arbitrary Detention. A perusal of the powers and
function vested in mayors would show that they are similar to those of a barrio captain except
that the barrio caption has smaller territorial jurisdiction. Having the same duty of maintaining
peace and order, both must be and are given the authority to detain or order detention. Even
Tuvera himself admitted that with the aid of his rural police, he as a barrio captain could have
led the arrest of Valdez. Hence, Tuvera can be charged with arbitrary detention.

9. Harry S. Stonehill, et al. vs. Hon. Jose W. Diokno, et al.

G.R. No. L-19550 | June 19, 1967
Concepcion, C.J.

Facts: Respondent judges issued a total of 42 search warrants against Harry S. Stonehill and
other petitioners to search the premises of their offices, warehouses, and/or residences and to
seize and take possession of their personal property which included books of accounts, financial
records, vouchers, correspondence, receipts, among others which are the subject of the
offense; stolen or embezzled and proceeds or fruits pertaining to a violation of Central Bank
Laws, Tariff and Customs Laws, Internal Revenue Code, and the Revised Penal Code.
Issue: Whether or not the contested warrants were issued upon probable cause and particularly
described the things to be seized

Held: No. The warrants were issued upon applications stating that the natural and juridical
person therein named had committed a "violation of Central Ban Laws, Tariff and Customs
Laws, Internal Revenue (Code) and Revised Penal Code." No specific offense had been alleged
in said applications. As a consequence, it was impossible for the judges who issued the
warrants to have found the existence of probable cause, for the same presupposes the
introduction of competent proof that the party against whom it is sought has performed particular
acts, or committed specific omissions, violating a given provision of our criminal laws. It would
be the legal heresy, of the highest order, to convict anybody of a "violation of Central Bank
Laws, Tariff and Customs Laws, Internal Revenue (Code) and Revised Penal Code," without
reference to any determinate provision of said laws. Hence, the warrants are null and void.

10. Jose Burgos, Sr., et al. vs. The Chief of Staff, et al.
G.R. No. L-64261 | December 26, 1984
Escolin, J.

Facts: Petitioners assail the validity of two search warrants under which "Metropolitan Mail" and
"We Forum" newspapers were searched, and office and printing machines, equipment and
other articles used in the printing, publication and distribution of the said newspapers, as well as
numerous papers and documents to be in the possession and control of petitioner Jose Burgos,
Jr., publisher-editor of the "We Forum" newspaper, were seized.

Issue: Whether or not there was sufficient basis for the finding of a probable cause upon which
a warrant may validly issue

Held: No. Probable cause for a search is defined as such facts and circumstances which would
lead a reasonably discreet and prudent man to believe that an offense has been committed and
that the objects sought in connection with the offense are in the place sought to be searched.
When the search warrant applied for is directed against a newspaper publisher or editor in
connection with the publication of subversive materials, as in the case at bar, the application
and/or its supporting affidavits must contain a specification, stating with particularity the alleged
subversive material he has published or is intending to publish. Mere generalization will not
suffice. Thus, the broad statement in Col. Abadilla's application does not satisfy the
requirements of probable cause. Bereft of such particulars as would justify a finding of the
existence of probable cause, said allegation cannot serve as basis for the issuance of a search
warrant and it was a grave error for respondent judge to have done so. Additionally, the search
warrants were in the nature of general warrants which made it constitutionally objectionable.
11. The People of the Philippines vs. Jose M. Baes
G.R. No. L-46000 | May 25, 1939
Concepcion, J.

Facts: Jose M. Baes, a parish priest of the Roman Catholic Church, charged the accused
Enrique Villaroca, Alejandro Lacbay and Bernardo del Rosario with an offense against religion
for causing the funeral of a member of the “Church of Christ” to pass through the churchyard
fronting the Roman Catholic Church, belonging to said church and devoted to the religious
worship thereof. The parish priest opposed this, but through force and threats of physical
violence by the accused, was compelled to allow the funeral to pass through the said
churchyard. Upon the remand of the case to the court, the fiscal filed a motion for dismissal,
denying that the unlawful act committed by the accused had offended the religious feelings of
the Catholics of the municipality.

Issue: Whether or not the act complained of constitutes the offense defined and penalized in
article 133 of the Revised Penal Code

Held: Yes. The facts alleged in the complaint constitute the offense defined and penalized in
article 133 of the Revised Penal Code. Whether or not the act is offensive to the religious
feelings of the Catholics is a question of fact which must be judged only according to the
feelings of the Catholics and not those of other faithful ones, for it is possible that certain acts
may offend the feelings of those who profess a certain religion, while not otherwise offensive to
the feelings of those professing another faith. Should the fiscal file an information alleging the
said facts and a trial be thereafter held at which the said facts should be conclusively
established, the court may find the accused guilty of the offense complained of.