GR L 1006; (June, 1949) (Digest)
G.R. No. L-1006; June 28, 1949
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FILEMON ESCLETO, defendant-appellant.
FACTS
Filemon Escleto was charged with treason before the People’s Court on three counts: (1) collaborating and fraternizing with Japanese forces by joining patrols and mounting guard duty; (2) accompanying Japanese patrols in search of guerrillas; and (3) arresting and delivering guerrilla Antonio Conducto to Japanese authorities on March 18, 1944, after which Conducto disappeared. The trial court acquitted Escleto on the first two counts for lack of concrete evidence but convicted him on the third count, finding that he had arrested Conducto and turned him over to the enemy. The prosecution’s evidence consisted mainly of testimonies from Conducto’s wife, Patricia Araya, and his mother, Sinforosa Mortero, who stated that Escleto stopped them on their way to town, took down their names, and escorted them to the garrison, where Conducto was detained and never seen again.
ISSUE
Whether the evidence presented by the prosecution is sufficient to prove the overt act of treason (arrest and delivery of Antonio Conducto to the enemy) as required by law, particularly the two-witness rule.
RULING
No. The Supreme Court reversed the conviction. The evidence failed to meet the stringent requirements for proving treason. The two-witness rule mandates that each overt act must be testified to by two witnesses. Here, the only point of agreement between the two witnesses was that Escleto took down names and accompanied the group to town. This act alone was ambiguous and could be interpreted as a barrio lieutenant performing a routine duty, not necessarily a treasonable act. The more damning testimony of Patricia Araya—that Escleto told a soldier, “This is Antonio Conducto who has firearm”—was uncorroborated by any other witness. Thus, no single overt act of treason was proven by the required two witnesses. The Court emphasized that the constitutional provision on treason is “severely restrictive” by design to make convictions difficult, protecting against unfounded accusations. Escleto was acquitted.
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