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People v.

Prieto
G.R. No. L-399 | January 29, 1948

Plaintiff: People of the Philippines


Defendant: Eduardo Prieto (Eddie Valencia)
Ponente: Tuason, J.

FACTS:
- Prieto was prosecuted in the People’s Court for 7 counts of treason. Initially, he pleaded not
guilty to every charge. Later on, he entered a plea of guilty to counts 1, 2, 3 and 7, and
maintained his original plea to counts 4, 5 and 6.
- The prosecutor only presented evidence to count 4 as he admitted insufficiency of evidence as
to counts 5 and 6. The court found him guilty to all counts except 5 and 6 of “treason
complexed by murder and physical injuries.”

ISSUE: What is the criminal liability of Prieto?

DECISION (Not guilty of count 4, guilty of treason in counts 1, 2, 3 and 7):


- Prieto is acquitted in count 4 as the of two-witness principle requirement was not satisfied.
They failed to corroborate each other:
o Juanito Albano testified that the accused and other Filipino undercovers and Japanese
officers caught an American aviator and had him carried to town on a sled pulled by a
carabao. That on the way, Prieto walked behind the sled and the American was taken
to the Kempetai headquarters.
o Valentin Cuison testified that he saw the accused following the American whose hands
were tied while walking and that he struck the flier with a rope. There was no mention
of a sled and nor did he see Juanito Albano.
- There is no crime of treason complexed with other felonies because these were not separate
offenses from treason.
o When a deed is charged as an element of treason, it becomes identified with it and
cannot be subject of a separate punishment, or used in combination with treason to
increase the penalty.
o Murder or physical injuries are charged as overt acts of treason and cannot be
regarded separately under their general denomination.
o But the brutality which accompanied the killing and the physical injuries are taken as
aggravating circumstances since it augmented the sufferings of the offended parties
unnecessarily to the attainment of the criminal objectives.
o But there is a mitigating circumstance of plea of guilty, hence, the punishment should
be reclusion perpetua.
- Other issue:
o There is a presumption in favour of legality and regularity of the proceedings and the
presumption that the accused was not denied of his rights.
o The fact that the attorney appointed to defend Prieto is reluctant to accept the
designation is not sufficient to overcome the presumption. The present counsel
“sincerely believes that the said Attorney Carin did his best, although it was not the
best of a willing worker.”

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