ANASTACIO LAUREL v.

ERIBERTO MISA

G.R. No. L-409

Date: 1947-01-30

FACTS:

Anastacio Laurel documented a request for habeas corpus. Laurel was then
charged for the crime of treason during the time of the Japanese colonization. With that
said, Laurel secures his appeal dependent on the hypothesis which explains that a
Filipino resident who clung to the adversary during the said Japanese era could not be
indicted with the crime of treason. This is as characterized and punished by Article 114
of the Revised Penal Code, for the reason as stated, “(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 these Islands upon the proclamation of the Philippine Republic.”

ISSUE:

Whether or not the sovereignty of the government of the Republic of the

Philippines was then considered suspended.

RULING:

The sovereignty of the government of the Republic of the Philippines was not
suspended.

RATIO DECIDENDI:

The allegiance of the Philippine citizens who, by that time, adhered to the enemy
by the adversary isn't annulled and cut off by foreign occupation. This is for the reason
that regardless of the occupier, sovereignty of the government will and always remain to
the country itself unless transferred to the said occupants.