Primary Holding

The Supreme Court found Alvero guilty of treason and affirmed the sentence of reclusion perpetua but increased the fine from ₱10,000 to ₱20,000.

Background

Aurelio Alvero was charged with 22 counts of treason before the People's Court for various collaborative activities with Japanese forces during the occupation of the Philippines in World War II. These activities included business dealings through ASA Trading, membership in pro-Japanese organizations, and military collaboration through groups like MAKAPILI and Bisig Bakal Ng Tagala.

Facts

• 1. Alvero established ASA Trading in August 1943, dealing in automobile spare parts and war materials
• 2. He joined KALIBAPI (Kapisanan sa Paglilinkod sa Bagong Pilipinas) on December 20, 1942
• 3. He helped organize the New Leader's Association with Japanese officials
• 4. He participated in founding MAKAPILI (Makabayang Kalipunan Ng Mga Pilipino)
• 5. He organized Bisig Bakal Ng Tagala as a military unit
• 6. He engaged in various propaganda activities supporting Japanese occupation
• 7. He wrote congratulatory letters to President Laurel regarding declaration of war against US and Britain

Arguments of the Petitioners

• 1. Alvero committed treason through economic collaboration by selling war materials to Japanese forces
• 2. He demonstrated political collaboration through membership in pro-Japanese organizations
• 3. He engaged in military collaboration by organizing and participating in military units supporting Japanese forces

Arguments of the Respondents

• 1. He claimed he was forced to join MAKAPILI
• 2. He argued his business dealings were not intended to aid the enemy
• 3. He maintained his actions were for maintaining peace and order
• 4. He cited valuable services rendered to Filipinos during occupation

Issues

• 1. Whether Alvero's business activities constituted economic collaboration
• 2. Whether his membership in various organizations constituted political collaboration
• 3. Whether his military activities constituted treason
• 4. Whether his acts showed adherence to the enemy

Ruling

• 1. Economic collaboration through ASA Trading was covered by Amnesty Proclamation No. 51
• 2. Political collaboration aspects were also covered by amnesty
• 3. Military collaboration through MAKAPILI and Bisig Bakal Ng Tagala constituted treason
• 4. Evidence of adherence to enemy was overwhelming

Doctrines

• 1. Two-witness rule in treason cases
• 2. Doctrine of adherence to the enemy
• 3. Principle that adherence alone without overt acts is not punishable
• 4. Application of amnesty to certain acts of collaboration

Precedents Cited

• 1. Laurel vs. Misa (G.R. No. L-409)
• 2. People vs. Carlos
• 3. People vs. Victoria
• 4. People vs. Garcia

Statutory and Constitutional Provisions

• 1. Amnesty Proclamation No. 51 (January 28, 1948)
• 2. Article 43 of Hague Conventions of 1907
• 3. Treason laws of the Philippines