PEOPLE v.

MANAYAO
G.R. No. L-322, July 28, 1947

FACTS: On 27th of January, 1945, the guerrillas raided the Japanese in Sitio Pulong Tindahan,
Municipality of Angat, Province of Bulacan. In reprisal for that said event, Manayao, member of the
Makapili, conspired together with his Japanese comrade soldiers to inflict terror upon the barrio of
Banaban in Bulacan where they killed 60 to 70 residents. Manayao alone killed about six women.
They killed the alleged to be supporters, wives and relatives of guerillas fighting the Japanese forces.
Manayao was positively identified by credible witnesses and he was later convicted with the high
crime of treason with multiple Murder. He was sentenced to death and to pay the damages. Appellant's
counsel contends that appellant was a member of the Armed Forces of Japan, was subject to military
law, and not subject to the jurisdiction of the People's Court; and in No. 2 he advances the theory that
appellant had lost his Philippine citizenship and was therefore not amenable to the Philippine law of
treason. Hence, Manayao cannot be tried under Philippine courts for any war crimes for only Japanese
courts can do so.
ISSUE: Whether or not Manayao by swearing allegiance to Japan may not to be liable for treason.
RULING: No. Manayaos swearing of allegiance to Japan was not proven as a fact nor is it proven
that he joined the Japanese Naval, Army or Air Corps. What he joined is the Makapili, which is a
group of Filipino traitors. The Court also emphasized that in times of war when the state invokes the
Constitutional provision which state The defense of the state is a prime duty of the government, in the
fulfillment of this duty all citizens may be required to render personal, military or civil service no one
can effectively cast off his duty to defend the state by merely swearing allegiance to an enemy country,
leaving and joining the opposite force, or by deserting the Philippine Armed Forces. Or even if
Manayao did lose his citizenship it is also indicated that no such person shall take up arms against his
native country; he shall be held guilty of a felony and treason, if he does not strictly observe this duty.
The court also said that such act would shock the conscience of any enlightened citizenry to say that
Manayao, by the very fact of committing the treasonous acts charged against him, the doing of which
under the circumstances of record he does not deny, divested himself of his Philippine citizenship and
thereby placed himself beyond the arm of our treason law. For if this were so, his very crime would be
the shield that would protect him from punishment.