People vs Alunan

Rafael Alunan is accused of treason because he accepted certain

appointments in the government during the regime of the Philippine
Executive Commission (Japanese Occupation Era) and
served/performed acts and duties in accordance with the positions he
accepted.
Among the positions/acts are as follows:
accepting and serving in the following positions: Minister of
Agriculture and Commerce; Member of the Executive Council;
Member of the Preparatory Commission on Philippine
Independence which drafted the 1943 Constitution; Minister of
Agriculture and Natural Resources; participating in a gratitude
mission to Tokyo;
voting in favor of declaration of war against the Allied Powers;
conferring with the Japanese emperor;
and helping draft and circulate a Letter of Response which
promised cooperation with the Japanese, among others.
W/N the accused is guilty of the crime of treason. NO
It is a basic rule that the crime of treason requires at least two
witnesses to every act. Therefore, other tests are merely secondary or
corroborative without merit or value for themselves in crimes of
treason.
There was much emphasis in identifying the signatures of the accused
in the documents presented, and even an expert witness to verify that
the signatures were made by the accused was presented. However,
this cannot override the general rule of at least two witnesses as
provided in the RPC.
Authenticity of the signatures on documents cannot be established by
ordinary means, but it requires the testimony of at least 2 witnesses
who saw the defendant materially sign. No such witnesses were
presented. The law is clear and specific in this regard.
Even if for the purposes of discussion that it was genuinely the
accused signatures, it does not constitute sufficient proof of
adherence to the enemy.
Although some of the charges or acts under the indictment, have
been established in the form and manner prescribed by law, such acts
were executed by the defendant in the performance of their official

duties, that is, by reason of the public office that played under
abnormal circumstances, and therefore can not be estimated as acts
proper support and comfort to the enemy cause. We are of opinion that
the mere acceptance of a public office and perform the functions and
duties attached thereto in and during the Japanese military occupation
of the Philippines, not per se crime of treason. But even accepting that
such acts alleged against the accused here were really helpful and
comfort to the enemy, are not punishable in this particular case, since
it has not been proven successful defendant's adherence to the enemy
because, as we have said above, is a prerequisite for a conviction for
the crime of treason.
Adherence to the enemy + acts that give the enemy aid and comfort
must concur for the accused to be convicted of treason. Mere
acceptance of a public office and performing the duties of such public
office during the Japanese military occupation does not prove
adherence to the enemy.