Mangahas vs.

People of the Philippines

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

FACTS: Cayetano Mangahas and Mariano de los Santos Mangahas were

accused of treason (Cases Nos. 742 and 744 of the Court of First Instance of
Bulacan). Around 11 a.m. on December 13, 1944 (a Saturday), Jose Perez
arrived to Martin de la Merced's home to inform him that a squad of 30 armed
Makapilis had raided Lawang and taken a number of guerrillas captive. When
Martin heard the tale, he sat down with other rebels and made his way out of
Makapilis and into the bushes. While his wife Enriqueta was exploring the house,
a second runner named Julian Payumo arrived and told her that Captain Basilio
Leonardo's home had already been raided. Shortly after, a third runner named
Lucio Ocampo arrived and informed her that the Makapilis were in front of the
municipal building. In order to view what they were going to do in her house,
she left her home and went to one across the street. 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.

De la Merced and Engracia de la Cruz confirmed to the aforementioned

overt acts. He was taken prisoner on December 30, 1944, and transported to the
Makapilis garrison by five persons. Three days after his detention, on January 2,
his wife Purita Ramos and her children, including Matias Legaspi, 11, visited the
Makapilis garrison where they met her husband. He hasn't returned, though, and
he hasn't been seen since. Purita Ramos and Matias Legaspi attested to the
aforementioned overt acts. The aforementioned evidence is used to support
counts Nos. 3 and 4 of the information against Mariano de los Santos Mangahas
as well as Nos. 2 and 3 of the information against Cayetano Mangahas. The two
defendants were among a group of armed Makapilis that stormed Primo S. Cruz's
residence in Norzagaray, Bulacan, in the early hours of December 29, 1944. They
took whatever they could get their hands on, including clothes, shoes, a helmet,
rice, and everything else they could find. Cruz was also taken into custody at the
same time, and the Japanese soldiers stationed at the San Jose garrison
shackled his hands and those of other prisoners before transporting them there.
On December 30, 1944, the defendants abducted Artemio Nicolas from his home
in Norzagaray, tied him up, and transported him to the poblacion before sending
him to the San Jose garrison; since then, he has not returned and has not been
seen. This tragedy also involved the defendants.
ISSUE:

Whether the defendant violates Article 114 of the Revised Penal Code by
committing treason.

RULING:

The Supreme Court has determined that the defendant is guilty of

treason. The Court ruled that the defendant committed treason by cooperating
with the enemy, even under duress. The Court emphasized that one of the
requirements for the crime of treason is to willingly support and comfort the
enemy. The defense's assertion of duress was rejected as a result of the
accused's inability to show that his actions were coerced. A lack of education was
supposed to lessen disloyalty in some circumstances but not in others. People v.
Cruz, G.R. L-2236, is the case at hand. On May 16, 1951, treason was not
reduced for lack of instruction; nonetheless, the minimum sentence stipulated by
law was maintained because it was determined that the defendants had not
contributed to the murders of the victims. The evidence does not support the
assertion that the appellant contributed to the victims' deaths. The result under
appeal is upheld, and the appellants will cover the associated 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

stationed at Imus, Cavite Province, who deserted on October 13, 1902, and was
apprehended on October 27, 1902. According to the inspector's testimony, when
he was apprehended, he told him that he had transferred the weapons he had
taken with him to his commander, Montalon. A commission designating him as a
second lieutenant, signed by Montalon and dated October 14, was discovered on
his person. The inspector served as the commission's sole witness for its
conclusions. There was proof that Montalon was engaged in an armed uprising
against the government in October and that there had been clashes that month
between his forces and those of the Constabulary.

No one in the Philippine Islands shall be found guilty of treason by any

tribunal, civil or military, under the authority of the United States, 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. According to the Congress's statute, a conviction is not possible
until two witnesses attest to the same overt act of treason. In this situation,
there is no such testimony. Only the defendant's departure and his capture were
mentioned in the government's evidence.

ISSUE:

Whether Simeon Magtibay, the accused, is a murderer.

RULING:

The judge concluded that Magtibay had committed murder. The court
regarded the witnesses' testimony as reliable and consistent. Additionally, the
court stated that Magtibay's claim of self-defense was unsupported by any
evidence. The killing was purposeful and unjustified, the court noted.
 Go Tian Sek Santos vs. Eriberto Misa

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

FACTS: The petitioner asserts that he is a Chinese national who was taken
hostage by the US Army's Counter Intelligence Corps in February 1945, turned
over to the Commonwealth Government in September, and is currently being
kept as a political prisoner by the respondent. He contends that his imprisonment
is illegal since he hasn't been accused of a crime or adjudged guilty by a judge of
a competent court and that Act No. 682 does not apply to him because he has
no allegiance to either the United States or the Commonwealth of the Philippines.
Speaking on behalf of the respondent, the Solicitor-General acknowledges the
petitioner's age as an alien and argues that even if he were to be charged with
espionage—a crime against national security for which allegiance is irrelevant—
he could be detained in accordance with Commonwealth Act No. 682. The
petitioner was detained for actively collaborating with the Japanese, according to
the Solicitor General. He doubts the claim of citizenship, nevertheless.

On the basis of the available evidence, the petitioner must be regarded as

a Chinese subject. According to the United States Army's commitment order No.
291, which was published, he fits this description. But that does not
automatically provide him the right to freedom. He is among those who are
taken into account by Commonwealth Act No. 682's section 19, which reads 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 nationality does not automatically
disqualify him from consideration.

ISSUE:

Whether the defendant violates Article 114 of the Revised Penal Code by
committing treason.

RULING:
 Santos' espionage conviction was upheld by the Supreme Court. The court
determined that the prosecution's evidence, which included intercepted radio
communications and witness testimony, proved Santos' guilt beyond a reasonable
doubt. The court also rejected Santos' statement that he was coerced into
sending the information, concluding that there was insufficient evidence to
support this claim.
 Javier Morilla Avellano vs. People of the Philippines

GR No. 189833, Feb 05, 2014

FACTS: In flagrante delicto, Javier Morilla and Mayor Ronnie Mitra of

Panukulan, Quezon were found smuggling shabu in an ambulance and a Starex
vehicle, respectively. The Starex van was able to pass through a checkpoint at
Real, Infanta Quezon, but police officers told the ambulance to stop. Police
officers then gave Morilla the order to unlock the car's back door so they could
inspect six sacks that Morilla said contained narra wooden tiles. When police
officers discovered that the contents were methamphetamine hydrochloride, they
pursued the Starex van. They were able to stop Mayor Mitra, who they
questioned about Morilla driving the ambulance with drugs. The fact that his van
was filled with bags similar to those recovered in the ambulance was plainly
visible to the investigators. They each carry a combined amount of shabu
weighing around 503.6 kg.

Both defendants maintained during the trial that they were unaware of
the contents of the car. Furthermore, Morilla claimed that the Information was
false and that he was not a member of the supposed organized or syndicated
gang because he merely followed the Mayor's directions. The trial court
determined that Morilla and Mitra were involved in a conspiracy and that their
shared goal was to convey illegal substances.

ISSUE:

Whether Javier Morilla Avellano is charged with a crime related to drugs.

RULING:

A conspiracy is established, according to the court, when two or more

people resolve to commit a crime after reaching an agreement about doing so.
(RCP, Article 8). A common intention to commit a crime is required to establish
conspiracy. The court determined that Morilla and Mayor Mitra had a shared
desire to carry the deadly substances, and that the totality of the factual facts in
this case support that judgment. He wouldn't have informed the police that he
was with Mayor Mitra if he wasn't really complicit in a plot with the mayor.
Transporting methamphetamine hydrochloride is illegal in and of itself since
doing so is punishable by a specific law. It is not necessary to provide evidence
of illegal intent, motive, or knowledge in order to carry sacks containing deadly
substances.
 Dela Pena vs. People of the Philippines

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

FACTS: The appellant, Maximo De La Pena, was charged with piracy, a

crime that is sanctioned by Presidential Decree (PD) No. 532. The accused
defendant submitted a not-guilty plea to the offense. His co-defendants, Romy
Real (Romy), Danny Real (Danny), and Onyong Reyes (Onyong), have not been
found and are still at large. When Julita Nacoboan (Julita), Jose Nacoboan
(Jose), and their son Marvin Nacoboan (Marwin) arrived, they were going to
board their pump boat, which was hauling 13 sacks of copra. These copra sacks
were intended to be placed onto a bigger passenger ship and transported there,
where the copra would be delivered to Catbalogan, Samar. A river that flows into
the ocean is close to their barangay. A smaller pump boat must be utilized to
transport the merchandise to a bigger passenger boat since the larger passenger
boat cannot dock along the shore when the tide is low. A smaller boat abruptly
blocked the way of the Nacoboan's pump boat as it was about to leave. Jose put
their pump boat's engine to a stop out of concern about a collision. The pump
boat was then quickly boarded by three armed men. Jose was told to move to
the aft, or back, of the boat by one of the armed guys who brandished a gun at
him. Jose's hands were bound and his head was covered when Julita recognized
him as the appellant. One thousand pesos in cash, two pairs of earrings, a
phone, and a necklace were all taken from Julita's bag by another armed
assailant. The pump boat was driven by another individual who anchored it on a
small island after traveling for over two hours. Marwin's shirt was taken off
during the journey, and it was used to blindfold Julita. The appellant discharged
the 13 sacks of copra as they got to the tiny island.

The pump boat was subsequently transported to another island by the

appellant and his armed companions, where its engine, propeller tube, and tools
were removed and placed onto the appellant's boat. As a result, the Nacoboan's
boat was left without an engine, forcing them to paddle to safety. They found
that they had already arrived at Equiran, Daram, and Samar. To report the
incident, Julita went to the police in Villareal, Samar. She stated that the engine
and other missing equipment were priced at P30,000.00 and that the cost of the
copra was P15.00 per kilogram at the time. Since she had known the appellant
for 16 years and recognized him when he boarded their boat, she identified him
as one of the armed men who had taken possession of it and removed its
engine, propeller tube, and equipment. Appellant asserted that he was a resident
of Brgy and refuted the charge leveled against him. 15 years in San Roque,
Villareal, and Samar. The RTC of Calbiga, Samar, Branch 33 issued a ruling
declaring the appellant guilty of piracy in accordance with PD 532. The CA
upheld the appellant's conviction for piracy under PD 532. The elements of piracy
under PD 532 were not established by the prosecution, according to the
appellant.

ISSUE:

Whether Mr. Dela Pena has been proven beyond a reasonable doubt guilty
of the robbery with homicide crime.

RULING:

The Supreme Court upheld Mr. Dela Pena's conviction for the robbery with
homicide offense. However, because Republic Act No. 9346 forbids the
application of the death penalty, the Court determines that the RTC's punishment
of reclusion perpetua without the possibility of parole was appropriate given that
the vessel and its cargo were seized by boarding the vessel.