Political Law

People of the Philippines vs Pedro Manayao

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G.R. No. L-322 – 78 Phil. 721 – Political Law – Constitutional Law – Citizenship – Defense of State – Treason

Pedro Manayao was a member of the Makapili (a group of Filipino traitors aiding the Japanese cause). Manayao conspired together with his Japanese comrade soldiers to inflict terror upon the barrio of Banaban in Bulacan where they killed 60 to 70 residents. The residents they killed were alleged to be supporters, wives and relatives of guerillas fighting the Japanese forces. Manayao was positively identified by credible witnesses and he was later convicted with the high crime of treason with multiple murder. He was sentenced to death and to pay the damages. Manayao’s counsel argued that his client cannot be tried with treason because Manayao has already lost his Filipino citizenship due to his swearing of allegiance to support the Japanese cause. Hence, Manayao cannot be tried under Philippine courts for any war crimes for only Japanese courts can do so.

ISSUE: Whether or not Manayao is guilty of treason.

HELD: No.¬†Manayao’s swearing of allegiance to Japan was not proven as a fact nor is it proven that he joined the Japanese Naval, Army or Air Corps. What he joined is the Makapili, a group of Filipino traitors pure and simple. The Supreme Court also emphasized that in times of war when the state invokes the Constitutional provision which state

The defense of the state is a prime duty of the government, in the fulfillment of this duty all citizens may be required to render personal, military or civil service…

no one can effectively cast off his duty to defend the state by merely swearing allegiance to an enemy country, leaving and joining the opposite force, or by deserting the Philippine Armed Forces. Or even if Manayao did lose his citizenship it is also indicated that no such person shall take up arms against his native country; he shall be held guilty of a felony and treason, if he does not strictly observe this duty.

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