G.R. No. L-1546; March 6, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUFINO SURALTA, defendant-appellant.

FACTS

The appellant, Rufino Suralta, a Filipino citizen and former USAFFE soldier, surrendered to and later joined the Japanese constabulary during the occupation, becoming a sergeant in command of the detachment in Palompon, Leyte. He was charged with treason on multiple counts. The People’s Court convicted him of the complex crime of treason with murder based on four counts: (1) In May 1944, he arrested three Filipinos who escaped forced labor and turned them over to the Japanese, who bayoneted them to death. (2) In June 1944, he ordered the arrest, tortured, and killed Simon Domayre, a guerrilla suspect. (3) In July 1944, he arrested and maltreated Nicanor Sy on suspicion of aiding guerrillas. (4) In June 1944, he arrested, tortured, and bayoneted to death Felix Tamayo, another guerrilla suspect.

ISSUE

Whether the appellant is guilty of treason and whether the penalty imposed by the People’s Court is correct.

RULING

Yes, the appellant is guilty of treason, but the penalty is modified. The Supreme Court affirmed the conviction for treason but held that the People’s Court erred in finding him guilty of a complex crime of treason with murder, as treason is a separate crime. The Court found the testimonies of prosecution witnesses credible and sufficient to satisfy the two-witness rule for treason. However, considering the appellant’s past service with the USAFFE and that he was a “mere tool of the Japanese,” the Court reduced the penalty from death to reclusion perpetua. The judgment was affirmed in all other respects, including the fines and indemnities.

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