Primary Holding

The Supreme Court upheld Paar’s conviction for treason, finding that his actions demonstrated adherence to the enemy. However, due to the lack of evidence proving that his actions led to the execution of individuals, the penalty was reduced from reclusion perpetua to a lesser term of imprisonment.

Background

The case arose from allegations that Teofilo Paar actively assisted the Japanese Military Police (Kempei Tai) in identifying, arresting, and interrogating individuals suspected of being part of the underground resistance movement. The prosecution pursued only four counts out of the original fifteen, focusing on Paar’s overt acts of treasonous collaboration with the enemy.

Facts

• 1. Affiliation with Kempei Tai: Paar worked for the Japanese Kempei Tai as an undercover agent between October 1944 and February 1945. Multiple witnesses testified that they saw him parading in the streets of Baguio in Kempei Tai uniform and armed with a .45 caliber pistol.
• 2. Arrests and Interrogations: Paar was responsible for the arrest and delivery of multiple individuals to the Japanese authorities. Patricia Guerrero, a waitress in Baguio, was arrested in October 1944 and detained until December 1944. Melquiades Valdez, a sanitary inspector, was arrested and tortured for allegedly disseminating radio broadcasts from San Francisco. Dr. Irineo Solano, a doctor, was arrested for suspected guerrilla activities and detained until January 14, 1945.
• 3. Defense Arguments: Paar claimed he was acting under the instructions of Major Laconico, a resistance operative, as a double agent. However, this claim was not supported by evidence, and his direct participation in Kempei Tai activities contradicted his defense.

Arguments of the Petitioners

• 1. Paar’s acts showed clear adherence to the enemy, aiding the Japanese in their efforts to suppress the resistance movement.
• 2. Testimonies of multiple witnesses established that Paar facilitated arrests and handed individuals over to the Japanese authorities.

Arguments of the Respondents

• 1. He did not intend to betray his country but was working as an undercover agent for the resistance.
• 2. His affiliation with the Kempei Tai was allegedly under orders from Major Laconico.
• 3. The evidence presented failed to satisfy the two-witness rule in certain counts.

Issues

• 1. Whether Paar’s acts constituted treason under Article 114 of the Revised Penal Code.
• 2. Whether Paar’s alleged intention of working for the resistance negated his liability for treason.
• 3. Whether the prosecution’s evidence satisfied the two-witness rule required in treason cases.

Ruling

• 1. His overt acts—such as arresting individuals and delivering them to the Kempei Tai—constituted treasonous adherence to the enemy.
• 2. His alleged affiliation with the resistance was unsubstantiated and contradicted by witness testimonies.
• 3. Although the evidence satisfied the legal standards for treason, his penalty was reduced due to the absence of proof that his actions resulted in executions.

Doctrines

• 1. Treason under Article 114 of the Revised Penal Code: Treason is committed by adhering to the enemies of the Philippines, giving them aid and comfort.
• 2. Two-Witness Rule: A conviction for treason requires that at least two witnesses testify to the same overt act of adherence to the enemy.
• 3. Adherence and Aid: Even in the absence of direct proof of intent, active participation in the enemy’s activities constitutes adherence.

Precedents Cited

• 1. People v. Abad Santos: Established that mere affiliation with the enemy is not enough; there must be an overt act of treason.
• 2. People v. Perez: Reiterated the necessity of the two-witness rule in treason cases.
• 3. People v. Victoria: Clarified the concept of adherence and aid as separate but interdependent elements of treason.

Statutory and Constitutional Provisions

• 1. Article 114 of the Revised Penal Code (Treason)
• 2. Philippine Constitution provisions on allegiance to the Republic