Mangahas vs.

People of the Philippines

G.R. No. L-5367 and L-5368, June 9, 1953

FACTS: Treason charges were brought against Cayetano Mangahas and

Mariano de los Santos Mangahas (Cases Nos. 742 and 744 of the Court of First
Instance of Bulacan). On December 13, 1944 (a Saturday), around 11 a.m., Jose
Perez showed up to Martin de la Merced's house and let him know that a group
of 30 armed Makapilis had raided Lawang and captured a number of guerrillas.
After learning of the story, Martin sat down with other rebels and fled from
Makapilis toward the bushes outside the town. While his wife Enriqueta was
looking around the house a second runner by the name of Julian Payumo came
and informed her that the house of Captain Basilio Leonardo had already been
raided, and not long after a third runner by the name of Lucio Ocampo came and
told her that the Makapilis were in front of the municipal building. She left her
house and went to another across the street from where she could see what
they were going to do in her house. The Makapilis, among whom were Cayetano
Mangahas, Mariano de los Santos Mangahas and Francisco Castillo, arrived,
surrounded the house, some of them went up; and took and brought to the
garrison of the Makapilis near the municipal building foodstuff intended for the
guerrillas at Victory Hill, consisting of 5 sacks of rice, 2 cans of salted beef, a
basketful of camote and another of tomatoes, a small bag of salt and a half sack
of sardines, salmon and corned beef.

Nicolette B. The aforementioned overt acts were attested to by de la

Merced and Engracia de la Cruz. On December 30, 1944, five people captured
him and carried him to the Makapilis garrison. His wife Purita Ramos, along with
her children, including Matias Legaspi, 11, went to the Makapilis garrison three
days after his detention, or on January 2, and there they saw her husband.
However, he hasn't been back and hasn't been seen since. The aforementioned
overt acts were attested to by Purita Ramos and Matias Legaspi. Both counts
Nos. 3 and 4 of the information against Mariano de los Santos Mangahas and
Nos. 2 and 3 of the information against Cayetano Mangahas are supported by
the aforementioned evidence. In the early hours of December 29, 1944, a group
of armed Makapilis, including the two defendants, raided Primo S. Cruz's home in
Norzagaray, Bulacan, taking everything they could get their hands on, including
rice, shoes, a helmet, clothes, and anything else they could find. They also
apprehended Cruz at the same time, and he and other people with their hands
bound were taken to the San Jose garrison, where Japanese soldiers were
stationed. A similar tragedy occurred to Artemio Nicolas, who was taken from his
home in Norzagaray by the defendants on December 30, 1944, tied up, and
carried to the poblacion before being sent to the San Jose garrison; ever since,
he has not been back and has not been seen.
ISSUE:

Whether the accused is guilty of treason under Article 114 of the Revised
Penal Code.

RULING:

The accused has been found guilty of treason by the Supreme Court.
According to the Court, the accused's cooperation with the enemy, even when
forced, amounted to treason. The Court highlighted that providing willing
assistance and comfort to the adversary is a requirement for the crime of
treason. Due to the accused's inability to demonstrate that his acts were forced,
the defense's claim of duress was dismissed. In some situations, a lack of
education was thought to diminish treason, but not in others. In the case People
v. Cruz, G.R. L-2236. On May 16, 1951, lack of instruction was not taken into
account to reduce treason, but because it turned out that the defendants had
not contributed to the victims' deaths, the minimum term required by law was
left in place. The claim that the appellant assisted in the victims' deaths is not
supported by the evidence. The appealed verdict is upheld, and the appellants
will pay the costs.
 US vs. Simeon Magtibay

G.R. No. L-1317, November 23, 1903

FACTS: It was established that he was a member of the Constabulary

assigned to the province of Cavite's Imus at the time of his defection on October
13, 1902, and that he was apprehended on that day. According to the inspector's
evidence, when he was apprehended, he told him that he had given his general,
Montalon, the weapons he had taken with him. A commission promoting him to
second lieutenant, dated October 14 and signed by Montalon, was discovered on
his person. The inspector was the sole eyewitness to this commission's
conclusions. There was proof that Montalon was engaged in an armed
insurrection against the government in October and that there had been clashes
between his soldiers and the forces of the Constabulary during that month.

According to Section 9 of the Act of Congress of March 8, 1902, "SEC. 9.

That no person in the Philippine Islands shall be convicted of treason by any
tribunal, civil or military, unless on the testimony of two witnesses to the same
overt act, or on confession in open court." Passing for the present the
defendant's testimony at the trial, there was no other evidence in the case to
show that he had ever joined the forces of the United States. A conviction is not
possible under the Congress's statute unless two witnesses can attest to the
same overt act of treason. Such testimony is not present in this instance. The
defendant's defection and capture were the only topics covered by the
Government's evidence.

ISSUE:

Whether the accused, Simeon Magtibay, is guilty of murder.

RULING:

Magtibay was found guilty of murder by the court. The testimony of the
witnesses was deemed trustworthy and consistent by the court. The court
further pointed out that Magtibay's claim of self-defense was unsupported by any
evidence. The intentionality and injustice of the killing were stressed by the
court.
 Go Tian Sek Santos vs. Eriberto Misa

G.R. No. L-319, March 28, 1946

FACTS: The petitioner claims to be a Chinese national who was seized in

February 1945 by the Counter Intelligence Corps of the US Army, handed over to
the Commonwealth Government in September, and has since been held as a
political prisoner by the respondent. He argues that this incarceration is unlawful
since he has not been charged with a crime or found guilty by a judge of a
competent court, and he is not eligible to be imprisoned under Act No. 682
because he has no allegiance to either the United States or the Commonwealth
of the Philippines. The Solicitor-General, speaking on behalf of the respondent,
concedes the petitioner's alien age and maintains that, even if he were to be
charged with espionage—a crime against national security for which allegiance is
irrelevant—he could be held in custody in accordance with Commonwealth Act
No. 682. The Solicitor-General also admits the petitioner's detention for active
collaboration with the Japanese. However, he disputes the allegation of
citizenship.

The petitioner must be considered a Chinese subject based on the

evidence at hand. He is so described in the United States Army's commitment
order No. 291, which was issued. But that does not mean that he is now entitled
to freedom. He is one of those considered by Commonwealth Act No. 682's
section 19, which says in part: "The Office of Special Prosecutors shall receive all
records, documents, exhibits, and other things that the Government of the
United States may have turned over in connection with and/or affecting said
political prisoners, examine the aforesaid records, documents, exhibits, etc., and
report to the Commonwealth Government on the status of the persons detained
by the Commander-in-Chief of the Armed Forces of the United States in the
Philippines as political prisoners. And further provided that the provisions of
Article 125 of the Revised Penal Code, as amended, shall be deemed suspended,
as they are hereby, with respect to the aforementioned political prisoners, until
the filing of the corresponding information with the People's Court, but the
period of suspension shall not be longer than six (6) months from the formal
delivery of said political prisoners by the Commande.” His foreign status does not
automatically disqualify him from the application of the aforementioned clauses.
According to the Solicitor-General, he could face charges under Commonwealth
Act No. 616 for espionage, a felony that is deemed to be a violation of national
security regardless of the offender's citizenship.

ISSUE:
 Whether the accused is guilty of treason under Article 114 of the Revised
Penal Code.

RULING:

The Supreme Court upheld Santos' espionage conviction. The court ruled
that Santos' guilt was proven beyond a reasonable doubt by the prosecution's
evidence, which included intercepted radio messages and witness testimony.
Santos' claim that he was forced into transferring the material was also dismissed
by the court, which held that there was no evidence to back up this assertion.
 Javier Morilla Avellano vs. People of the Philippines

GR No. 189833, Feb 05, 2014

FACTS: Mayor Mitra, Willie Yang, and Ruel Dequilla were apprehended
during a checkpoint trafficking methamphetamine hydrochloride unlawfully in
two (2) motor vehicles, namely a Starex van with a commemorative plate that
read "Mayor" and a municipal ambulance. Mayor Mitra said throughout the trial
that he had no clue of what was in the sacks and that he had only complied with
the request of a certain Ben Tan because the latter had purchased his fishing
boat. Morilla similarly stated that he believed Dequilla and the wooden tiles and
electronic spare parts he was delivering were what they were. Yang, the other
ambulance passenger, should be excused for not bothering to ask about the
contents of the car as all he was doing was being a passenger.

ISSUE:

Whether the accused, Javier Morilla Avellano, is accused as guilty in drug

case.

RULING:

The court determined that a conspiracy occurs when two or more people
resolve to commit a crime after reaching an agreement on doing so. (RPC, Article
8). There must be a shared intention to commit a crime in order to establish
conspiracy. In this case, the court decided that all of the relevant facts point to a
conclusion that Morilla and Mayor Mitra planned to transfer the deadly
substances together. He wouldn't have told the police that he was working with
Mayor Mitra if he wasn't actually a part of a plot. Since it is illegal to transport
methamphetamine hydrochloride because of a specific statute, doing so is itself
illegal. There is no requirement that there be evidence of criminal knowledge or
purpose in order for the transportation of the sacks containing deadly medicines
to be proven.
 Dela Pena vs. People of the Philippines

G.R. No. 219581, January 31, 2018

FACTS: Maximo De La Pena, the appellant, was accused of piracy, which is

punishable under Presidential Decree (PD) No. 532. Appellant entered a not-
guilty plea to the charged crime. Romy Real (Romy), Danny Real (Danny), and
Onyong Reyes (Onyong), his co-defendants, have not been apprehended and are
still at large. They were about to board their pump boat, which was carrying 13
sacks of copra, when Julita Nacoboan (Julita), her husband Jose Nacoboan
(Jose), and their son Marvin Nacoboan (Marwin) arrived. These copra sacks were
meant to be loaded and moved to a larger passenger vessel, which would then
transport the copra to Catbalogan, Samar. Their barangay is located next to a
river that empties into the ocean. The goods must be transported to a larger
passenger boat using a smaller pump boat when the tide is low since the larger
passenger boat cannot dock near the coast. A smaller boat abruptly obstructed
the Nacoboan's pump boat as it was about to depart. Jose shut down the engine
of their pump boat out of concern about a collision. The pump boat was then
quickly jumped by three armed men. Jose was told to move to the rear or aft
side of the boat by one of the armed men who brandished a gun in his direction.
Jose's wrists were tied, and he had a hat on, so Julita recognized him as the
appellant. The following goods were taken from Julita's luggage by an additional
armed assailant: 1) P1,000.00 in cash; 2) Earrings; 3) Cell phone; and 4)
Necklace. The pump boat was driven by another person, and it arrived at a little
island after over two hours of journey. Marwin's shirt was removed during the
journey and Julita was blindfolded. The appellant unloaded the 13 sacks of copra
when they reached the little island.

The pump boat was then transported to another island by the appellant
and his armed companions, where its engine, propeller tube, and tools were
taken and placed onto the appellant's boat. The Nacoboan's boat was
consequently left without an engine, forcing them to paddle to safety. They
learned they had already arrived at Equiran, Daram, and Samar. To report the
event, Julita went to the police station in Villareal, Samar. She stated that the
engine and other missing equipment were valued at P30,000.00 and that the
cost of the copra at the time was P15.00 per kilogram. She recognized the
appellant when he boarded their boat because she had known him for 16 years
and believed he was one of the armed guys who had taken possession of it and
removed its engine, propeller tube, and equipment. The appellant asserted that
he lived in Brgy and refuted the allegations made against him. For fifteen years,
San Roque, Villareal, and Samar. The appellant was found guilty of piracy under
PD 532 by the RTC of Calbiga, Samar, Branch 33, which issued judgment. The
appellant's conviction for piracy under PD 532 was upheld by the CA. The
prosecution, in the appellant's opinion, failed to establish the elements of piracy
as defined by PD 532.

ISSUE:

Whether the accused, Mr. Dela Pena, is convicted of robbery with

homicide beyond a reasonable doubt.

RULING:

The appeal lacks merit. The Information also clearly alleged that the
vessel's cargo, equipment, and personal belongings of the passengers were
taken by the appellant and his armed companions. The Court finds that the
prosecution was able to establish that the victims' pump boat was in Philippine
waters when appellant and his armed companions boarded the same and seized
its cargo, equipment, and the personal belongings of the passengers. The Court
finds no reason to doubt the testimony of Julita identifying appellant as one of
the assailants who boarded their vessel and seized its cargo, equipment, and the
passengers' personal belongings. Julita testified that she was able to identify
appellant because of the moonlight that illuminated the area. Hence, from the
provision above, the proper imposable penalty should be death. However, due to
Republic Act No. 9346, which prohibits the imposition of the death penalty, the
Court thus finds that the penalty imposed by the RTC, which was reclusion
perpetua without eligibility for parole, was correct since the seizure of the vessel
and its cargo was accomplished by boarding the vessel.