Primary Holding

The Supreme Court held that when murder or physical injuries are charged as overt acts of treason, they cannot be regarded separately under their general denomination. The brutality of killing or physical injuries may be considered an aggravating circumstance but not as a separate crime.

Background

The case arose from actions committed during the Japanese occupation of the Philippines in 1944-1945. The accused, Eduardo Prieto, acted as an undercover agent for the Japanese Military Police, participating in various activities against suspected guerrillas and their supporters.

Facts

• 1. Eduardo Prieto was charged with seven counts of treason
• 2. He pleaded guilty to counts 1, 2, 3, and 7
• 3. The prosecution presented evidence only on count 4
• 4. Counts 5 and 6 were abandoned due to insufficient evidence
• 5. The accused participated in multiple incidents: (1) October 15, 1944: Led Japanese soldiers to apprehend Abraham Puno (2) October 28, 1944: Apprehended Guillermo and Macario Ponce (3) November 1944: Led patrol resulting in death of Damian and Santiago Alilin (4) November 16, 1944: Involved in torture of Antonio Soco and killing of Gil Soco

Arguments of the Petitioners

• 1. The prosecution argued that the accused committed: (1) A complex crime of treason with murder and physical injuries (2) Multiple overt acts showing adherence to the enemy (3) Actions that constituted both treason and separate crimes of murder

Arguments of the Respondents

• 1. The defense counsel sought reversal based on: (1) The trial court's failure to appoint another attorney de oficio (2) The expressed reluctance of the appointed counsel to defend the accused

Issues

• 1. Whether murder and physical injuries charged as elements of treason can be treated as separate crimes
• 2. Whether the accused was denied effective counsel
• 3. Whether the two-witness rule was satisfied for count 4

Ruling

• 1. Murder and physical injuries, when charged as elements of treason, become part of the treason and cannot be punished separately
• 2. The brutality of the killings constitutes an aggravating circumstance
• 3. The aggravating circumstance is offset by the mitigating circumstance of guilty plea
• 4. The accused was not denied effective counsel
• 5. Count 4 was not proven due to failure to satisfy the two-witness rule

Doctrines

• 1. Two-witness rule in treason cases: Requires two witnesses to testify to the same overt act of treason
• 2. Complex crimes doctrine: When murder is an element of treason, it cannot be punished separately
• 3. Presumption of regularity: Courts presume proper legal representation unless proven otherwise

Precedents Cited

• 1. People vs. Adriano (44 Off. Gaz., 4300): Referenced for the two-witness principle
• 2. Cramer vs. U.S. (65 S. Ct. 918): Cited regarding the nature of giving aid and comfort
• 3. U.S. vs. Labial (27 Phil., 82): Used to support presumption of legality in court proceedings
• 4. U.S. vs. Escalante (36 Phil., 743): Cited regarding procedural presumptions

Statutory and Constitutional Provisions

• 1. Philippine Treason Law
• 2. Article 48 of the Revised Penal Code
• 3. Article 14, paragraph 21 of the Revised Penal Code (aggravating circumstances)