Primary Holding

The Supreme Court held that membership in Makapili, while constituting an overt act of treason, must be proven by two witnesses testifying to the same specific instance, not different occasions of membership.

Background

During the Japanese occupation of the Philippines between January and April 1945, Apolinario Adriano was accused of treason for joining the Makapili organization and allegedly participating in various activities supporting Japanese forces against the United States and Philippine Commonwealth forces.

Facts

• 1. Adriano was charged with treason for actions between January and April 1945
• 2. He allegedly joined Makapili, a pro-Japanese military organization
• 3. Multiple witnesses testified to seeing him in Makapili uniform with weapons on different occasions
• 4. He was accused of participating in raids and property confiscation
• 5. Witnesses claimed he performed sentry duty at Japanese garrisons
• 6. He allegedly retreated with Japanese forces to the mountains upon liberation
• 7. He later surrendered to American forces while armed

Arguments of the Petitioners

• 1. Mere membership in Makapili constitutes both adherence to the enemy and giving aid and comfort
• 2. Multiple witnesses testified to seeing the accused in Makapili uniform on different occasions
• 3. The accused's activities demonstrated active participation in enemy operations

Arguments of the Respondents

• 1. Mere membership in Makapili constitutes both adherence to the enemy and giving aid and comfort
• 2. Multiple witnesses testified to seeing the accused in Makapili uniform on different occasions
• 3. The accused's activities demonstrated active participation in enemy operations

Issues

• 1. Whether membership in Makapili constitutes an overt act of treason
• 2. Whether the two-witness rule is satisfied by different witnesses testifying to similar acts on different occasions

Ruling

• 1. The Supreme Court reversed the conviction because: (1) The two-witness rule requires testimony about the same specific overt act (2) Different witnesses testifying to similar acts on different occasions is insufficient (3) The rule is intentionally restrictive to protect against false accusations (4) Natural inferences cannot substitute for direct testimony

Doctrines

• 1. Two-Witness Rule in Treason Cases: Requires two witnesses to testify to the same overt act, not separate instances
• 2. Overt Act Requirement: Each specific act of treason must be independently proven by two witnesses
• 3. Adherence to Enemy: Can be proven by one witness or circumstantial evidence, unlike overt acts

Precedents Cited

• 1. Cramer vs. United States (65 Sup. Ct., 918): Established minimum requirements for overt acts in treason cases
• 2. United States vs. Robinson (D.C.S.D., N.Y., 259 Fed., 685): Defined requirements for witness testimony in treason cases

Statutory and Constitutional Provisions

• 1. Philippine law on treason (derived from Anglo-American law)
• 2. Constitutional provision requiring two witnesses