G.R. No. L-2256; July 6, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUIS NAVEA, defendant-appellant.

FACTS

The appellant, Luis Navea, was convicted by the People’s Court of treason based on three counts. Under count 1, he was alleged to have piloted a banca used by a party that captured an American flier, Lieutenant Leslie, who was later liquidated by Japanese soldiers. Under count 2, he and another, clad in Japanese uniforms, arrested Wenceslao Carpena as a guerrilla suspect; Carpena was later killed. Under count 4, he participated in the arrest and subsequent bayoneting to death of Agustin Ramirez, also a guerrilla suspect. The trial court found him guilty of counts 1, 2, and 4 and sentenced him to life imprisonment.

ISSUE

Whether the trial court erred in convicting the appellant of treason.

RULING

The Supreme Court modified the conviction. It acquitted the appellant under count 1, finding he was merely compelled to pilot the banca and took no active part in the capture or liquidation, thus entitling him to the benefit of reasonable doubt. However, the Court affirmed his guilt under counts 2 and 4, as each was supported by at least two witnesses, and discrepancies in their testimonies were on minor details only, not undermining their credibility. The Solicitor General’s recommendation to sentence him for the complex crime of treason with murder was rejected, as the killing was an element of the treason charged and cannot be punished separately or used to increase the penalty. The appealed judgment was affirmed with costs.

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