G.R. No. L-322; July 28, 1947
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO MANAYAO, ET AL., defendants. PEDRO MANAYAO, appellant.

FACTS

Appellant Pedro Manayao, along with Filomeno Flores and Raymundo Flores, was charged with treason with multiple murder before the People’s Court. Only Manayao was tried as the others were not apprehended. He was convicted and sentenced to death, with aggravating circumstances, a fine, indemnities, and costs. The charges stemmed from events on January 29, 1945, in Barrio Banaban, Angat, Bulacan. In reprisal for a guerrilla raid, Japanese soldiers and Filipino Makapili members, including Manayao, gathered about sixty to seventy residents (men, women, and children) behind the barrio chapel. The surrounding houses were set on fire, and the assembled adults were killed. Appellant personally bayoneted about six women, including Patricia and Dodi, despite their pleas for mercy, stating no mercy would be given as they were wives of guerrillas. He also proposed killing the small children, but the Japanese soldiers interceded and spared them. The prosecution’s case relied on the testimonies of eye-witnesses, including two ten-year-old girls, Maria Paulino and Clarita Perez, and Policarpio Tigas, as well as appellant’s own sworn statements admitting participation.

ISSUE

The primary legal issues raised by the appellant were: (1) whether he, as a member of the Makapili, was part of the Japanese Armed Forces and thus subject to military law and not the jurisdiction of the People’s Court; and (2) whether he had lost his Philippine citizenship and was therefore not amenable to the Philippine law of treason.

RULING

The Supreme Court affirmed the conviction but modified the penalty. It rejected both of appellant’s contentions. First, it ruled that the Makapili was not a part of the Japanese Army but was an organization of Filipino traitors. Second, it held that appellant did not lose his Philippine citizenship under Commonwealth Act No. 63 , as there was no evidence he subscribed to an oath of allegiance to support Japan’s constitution or laws, accepted a commission in Japan’s military service, or was declared a deserter from the Philippine military. The Court emphasized the constitutional duty of citizens to defend the State. The facts of the massacre were deemed clearly established by credible eyewitness testimony and appellant’s own confessions. However, while believing the appellant was present and participated, the Court, expressing some reservation about accepting all details of the child witnesses’ testimonies due to their tender age and susceptibility, modified the penalty from death to reclusion perpetua.