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Updated 22nd March 2025
People vs. Agpangan
A treason case where the Supreme Court acquitted the defendant due to the prosecution's failure to satisfy the two-witness rule in proving treasonous overt acts, and due to compelling evidence that the defendant's actions were done under duress after the Japanese killed a guerrilla member in his house and threatened him with the same fate.

Primary Holding

The Supreme Court reversed the lower court's decision and acquitted the appellant, finding that the prosecution failed to prove beyond reasonable doubt the alleged treasonous acts under the two-witness rule requirement, and that evidence suggested the appellant acted under duress.

Background

The case arose during the Japanese occupation of the Philippines in World War II. The defendant was accused of being a member of pro-Japanese organizations (Ganap and Pampars) and performing duties that aided the Japanese forces against Filipino and American forces between December 1944 and January 1945 in Laguna Province.

History

  • The case originated in the People's Court where the defendant was found guilty of treason

  • The defendant was sentenced to reclusion perpetua with accessory penalties and a fine of ₱10,000

  • The case was appealed to the Supreme Court

  • The Supreme Court rendered its decision on October 10, 1947

Facts

  • 1. The defendant was accused of being a member of Ganap, a pro-Japanese organization, and joining the Pampars, a military organization supporting the Japanese Army
  • 2. He was allegedly equipped with a 1903 Springfield rifle and underwent 10 days of military training
  • 3. From January 12, 1945, to March 15, 1945, he was assigned to weekly guard duty
  • 4. Three prosecution witnesses testified about seeing him perform various duties at the Japanese garrison
  • 5. The defendant's own son, Bienvenido Agpangan, was among those executed by the Japanese
  • 6. The defendant testified that he was coerced into working for the Japanese after they killed a guerrilla member (Vicente Auxilio) in his house

Arguments of the Petitioners

  • 1. The prosecution presented three witnesses who testified about the defendant's activities at the Japanese garrison
  • 2. They claimed he performed guard duty, confiscated food supplies, and participated in arrests of suspected guerrillas
  • 3. They asserted he was a willing member of pro-Japanese organizations

Arguments of the Respondents

  • 1. The defendant claimed he was coerced into working for the Japanese after they killed Vicente Auxilio in his house
  • 2. He argued that his compliance was solely to save his life
  • 3. He pointed to the fact that the Japanese killed his own son as evidence of his lack of genuine adherence to their cause

Issues

  • 1. Whether the prosecution proved the alleged treasonous acts beyond reasonable doubt under the two-witness rule
  • 2. Whether the defendant's actions constituted separate overt acts of treason or were part of one continuous act
  • 3. Whether the evidence supported the defendant's claim of duress

Ruling

  • 1. The Supreme Court ruled in favor of the defendant based on: (1) The prosecution's failure to satisfy the two-witness rule, as no two witnesses testified to the same specific overt act (2) The credibility of the defendant's claim of duress, supported by the execution of his own son by the Japanese (3) The reasonable doubt created by the contradictory testimonies of the prosecution witnesses

Doctrines

  • 1. Constitutional Presumption of Innocence: The accused shall be presumed innocent until proven guilty beyond reasonable doubt
  • 2. Two-Witness Rule in Treason Cases: Each overt act must be proved by at least two witnesses testifying to the same specific act
  • 3. Doctrine of Duress: Actions committed under threat of death or serious bodily harm may negate criminal intent

Precedents Cited

  • 1. People vs. Alarcon (G.R. No. L-407): Used to establish that certain acts may constitute parts of a single continuous treasonous act rather than separate overt acts
  • 2. U.S. vs. Manalo (6 Phil., 364): Cited to establish that mere acceptance of a commission in a traitorous army is insufficient to constitute treason
  • 3. U.S. vs. Villariño (5 Phil., 697): Referenced regarding requirements for overt acts in treason
  • 4. U.S. vs. De los Reyes (3 Phil., 349): Used to support requirements for proving treason
  • 5. U.S. vs. Magtibay (2 Phil., 703): Cited regarding elements necessary for treason conviction

Statutory and Constitutional Provisions

  • 1. Article II, Section 1(17) of the Constitution: Presumption of innocence
  • 2. Article 114 of the Revised Penal Code: Two-witness rule in treason cases