LAUREL V. MISA, GR NO. L-409, JANUARY 30, 1977
FACTS: Sometime in May 1945, Anastacio Laurel, herein petitioner, a Filipino citizen, was arrested by the US Army
and was interned, under a commitment order ―for his active collaboration with the Japanese during the Japanese
occupation. He was charged with treason as defined and penalized by Art. 114 of the Penal Code. However, in
September 1945, he was turned over to the Commonwealth government and since then he has been under the custody
of the Director of Prisons. Petitioner then filed a petition for habeas corpus mainly asserting that he cannot be
prosecuted for the crime of treason for the reason (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.
ISSUES: Whether the sovereignty of the legitimate government in the Philippines and, consequently, the correlative
allegiance of Filipino citizens were suspended during the Japanese occupation.
Whether the petitioner can be prosecuted for the crime of treason by giving aid and support to the enemy during the
Japanese occupation.
HELD: NO. The absolute and permanent allegiance of the inhabitants of a territory occupied by the enemy to their
legitimate government or sovereign is not abrogated or severed by the enemy‘s occupation, because the sovereignty
of the government or sovereign de jure is not transferred thereby to the occupier and if it is not transferred to the
occupant it must necessarily remain vested in the legitimate government; that the sovereignty vested in the titular
government must be distinguished from the exercise of the rights inherent thereto, and may be destroyed, or severed
and transferred to another, but it cannot be suspended because the existence of sovereignty cannot be suspended
without putting it out of existence or divesting the possessor thereof at least during the so-called period of suspension;
that what may be suspended is the exercise of the rights of sovereignty with the control and government of the territory
occupied by the enemy passes temporarily to the occupant; x x x and that as a corollary of the conclusion that the
sovereignty itself is not suspended and subsists during the enemy occupation, the allegiance of the inhabitants to their
legitimate government or sovereign subsists, and therefore there is no such thing as suspended allegiance.
YES. Article 114 of the Revised Penal Code was 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‘s occupation. Just as a citizen or subject of a government or sovereign may be prosecuted for
and convicted of treason committed in a foreign country, in the same way a inhabitant of a territory occupied by the
military forces of the enemy may commit treason against his own legitimate or sovereign if he adheres to the enemies
of the latter by giving them aid and comfort.
PEOPLE V. ADLAWAN, GR NO. L-456, MARCH 29, 1949
PEOPLE V. AGPANGAN, GR NO. L-778, OCTOBER 10, 1947
FACTS: Agpangan stands accused of treason, committed between December 1944 and January 1945 in the
Province of Laguna when he allegedly joined the Pampara military organization which supported the Japanese Army.
He was seen doing guard duty in the Japanese garrison “many times” or more than “ten times” according to two of
the three witnesses, Serrano and Adaro, who testified for the prosecution.
ISSUE: Whether or not the prosecution meets the test under the two-witness rule to convict Agpangan of treason?
RULING: No, the prosecution did not meet the test. To meet the test, two witnesses, at least, shall have testified as to
the perpetration of a single but the same and precise treasonous overt act. In this case, the first2witnesses testified they
had seen Agpagan “many times” but neither mentioned any specific time, day and hour. There is no way to conclude
that they refer to the same overt act. Moreover, the prosecution’s case was further weakened by the third witness’
testimony that Agpangan did the guard duty in Makapili garrison which is 1 kilometer away from the Japanese garrison
referred to by the first 2 witnesses.
US V. MANALO, GR NO. L-2723, AUGUST 9, 1906
PEOPLE V. DELA PEÑA, GR NO. 219581, JANUARY 31, 2018
PEOPLE V. ARANETA, GR NO. 24622, JANUARY 31, 2018
CALLEJA V. EXECUTIVE SECRETARY, GR NO. 252571, JUNE 15, 2021
PEOPLE V. GUANZON, GR NO. 119574, MARCH 19, 1998
LAGMAN V. MEDIALDES, GR NO. 231658, JULY 4, 2017
PEOPLE V. HEMADY, GR NOS. L-6025-26, JULY 18, 1956
ESPIRITU V. LIM, GR NO. 85721, OCTOBER 3, 1991
PEOPLE V. NABONG, GR NO. 36426, NOVEMBER 3, 1952
PEOPLE V. PEREZ, GR NO. 21049, DECEMBER 22, 1923
ESPUELAS V. PEOPLE, GR NO. L-2990, DECEMBER 17, 1951
PONSICA V. IGNALAGA, GR NO. L-72301, JULY 31, 1987
ENRILE V. SALAZAR, 186 SCRA 217