G.R. No. L-23465 October 31, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CASTO ALEJANDRINO alias “TORRES” alias “GUAN YEK” alias “GY” alias “G.I” alias “TATANG”, defendant-appellant.

FACTS

The defendant-appellant, Casto Alejandrino, was convicted by the lower court for violating the Anti-Subversion Act ( Republic Act No. 1700 ). The prosecution presented evidence detailing his membership and activities within the Communist Party of the Philippines. Crucially, Alejandrino himself made a judicial admission of his party membership. During a hearing, he submitted a written petition for postponement stating he was not denying his membership in the party outlawed by R.A. 1700, effectively admitting his affiliation after the law’s effectivity.
The prosecution’s evidence further established specific overt acts. Multiple witnesses testified to Alejandrino’s presence and leadership at Huk conferences in Telabastagan, Pampanga in March 1958 and in Biak-na-Bato, Bulacan in November 1957. Witnesses also recounted an armed encounter in Telabastagan in March 1958, where Alejandrino led a group of Huks, exchanged fire with government troops, and exhorted his men to fight. After the prosecution rested, the accused waived his right to present testimonial evidence in his defense.

ISSUE

The primary issues were: (1) the constitutionality of the Anti-Subversion Act, and (2) whether the prosecution’s evidence, particularly regarding the overt acts, satisfied the two-witness rule required for conviction under the said law.

RULING

The Supreme Court affirmed the conviction. On the constitutional challenge, the Court held that the question of the Anti-Subversion Act’s validity had already been settled in People v. Ferrer, which upheld the law against claims it was an ex post facto law and that it violated freedoms of speech and assembly. The Court considered this matter foreclosed, respecting the doctrine of stare decisis despite noted dissents within the Tribunal.
On the sufficiency of evidence, the Court ruled that the prosecution complied with the two-witness rule. The trial court correctly found that multiple witnesses testified to each of the three overt acts: the March 1958 Telabastagan conference, the November 1957 Biak-na-Bato conference, and the March 1958 armed encounter. The accused’s own judicial admission conclusively proved his membership in the outlawed party. By waiving the presentation of defense evidence, the case was decided solely on the prosecution’s proof, which the Court found more than sufficient to establish guilt beyond reasonable doubt. The Court deferred to the trial court’s factual findings, noting no circumstance was overlooked or misinterpreted. The judgment of conviction was therefore affirmed.