People v.

Caña
87 Phil. 577

Facts:
Defendant Eleuterio Caña was charged in the People’s Court with treason. He
committed treasonous acts such as acting puppet mayor of the Japanese in the municipality of
Abuyog, Leyte where he forced the people there to dig trenches and build stables for the
Japaneses Armed Forces. He also told the people of Abuyog that the Americans would not
return to the Philippines and that he was not afraid of the Filipino soldiers and guerillas
because the Japanese Armed Forces were behind him. He provided the Japanese soldiers with
houses to live and ejected the Filipino civilians out of their houses to give room to the Japanese.
In his defense, Caña argued that he did not do such acts with free will, but under the
compulsion by the Japanese officer of the garrison. He also said that he acted merely as
interpreter of the Japanese officer who spoke at the meetings held in the barrios. The lower
court convicted him of treason and sentenced him to 15 years of reclusion temporal. On appeal,
the appellate court opined that the penalty applicable is reclusion perpetua

Issue:
Whether or not the penalty imposed by the appellate court is proper.

Held:
NO. Even though defendant committed treasonable acts making him liable for treason,
the lower penalty should be imposed upon him. The Revised Penal Code provides that any
Filipino citizen who levies war against the Philippines or adheres to her enemies by giving them
aid or comfort within the Philippines or elsewhere should be held liable for treason. In the given
case, the witnesses procured by the prosecution all point to the guilt of the defendant. The guilt
of the accused has been proven beyond reasonable doubt. As to the penalty imposed, since
there has been no killing, not even torture of prisoners, at least not on the part of the appellant;
the penalty should be reclusion temporal only. Treason is a very serious crime committed during
war by one who, forgetting his loyalty and oath of allegiance to his own country, aids the
enemy and gives it aid and comfort. The amount or degree of said aid or comfort given the
enemy as well as the gravity of the separate and distinct acts of treason committed by the
accused, rather than the circumstance aggravating or mitigating attending its commission,
determine the degree of the penalty to be imposed. Premises considered, the correct penalty
was the one sentenced by the lower court.