G.R. No. L-49 – 75 Phil. 285 – Political Law – Constitutional Law – General Principles – Elements of a State – Sovereignty – Change of Sovereignty; Effect on Political Laws – Postliminium
During the Japanese occupation, Act No. 65 was caused to be passed by the Japanese. This law increased the penalty of robbery of goods to a minimum of life imprisonment to a maximum of death. William Peralta, a member of the Manila Constabulary, was accused of having violated Act No. 65. He was found guilty and was sentenced to suffer life imprisonment. Peralta then filed a petition for habeas corpus. He argued that Act No. 65 is a law of political color and that the same was abrogated when the Philippines was liberated from the Japanese by the Americans.
ISSUE: Whether or not Peralta is correct.
HELD: Yes. But the Supreme Court clarified: Act No. 65 was a valid law. The belligerent occupant (the Japanese) was expected to promulgate laws to protect itself and its military. The purpose of the law was to control supply and to avoid goods reaching the guerillas fighting them; the law was for a political purpose; hence it is a law of political complexion. All judgments of political complexion of the courts during the Japanese regime, ceased to be valid upon the reoccupation of the islands by virtue of the principle of postliminium. The sentence which convicted Peralta of a crime of a political complexion must be considered as having ceased to be valid ipso facto upon the reoccupation or liberation of the Philippines by General Douglas MacArthur.
