CASE No.

6 (Treason)
G.R. No. L-9529

August 30, 1958

THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

vs.
PEDRO T. VILLANUEVA, defendant-appellant.
FACTS:
During the Japanese occupation, appellant Pedro T. Villanueva, a Filipino citizen owing allegiance to the United
States of America and the Commonwealth of the Philippines, gave the enemy aid and comfort by rendering service
with the Japanese Imperial Army as secret agent, informer and spy, of its Detective Force in the province of Iloilo,
and that in the performance of such service, he participated actively and directly in the punitive expeditions
periodically made by the Japanese forces in the guerilla-infested areas of the province of Iloilo, and committed
robberies, arson and mass-murders.
Witnesses, who themselves were victims of the maltreatment and torture of the Japanese and others who were able
to escape the raids made by the Japanese forces with the aid of Villanueva, testified with corroborated statements
against the defendant.
The defendant denied the overt acts imputed upon him, and avers that if he ever served in the detective force of the
Japanese Army, it was because he was made to accept the position under duress, and that his acceptance of such
position was for the good of the people, he having saved many Filipino lives from Japanese atrocities.
Villanueva was sentenced to death by the People's Court for the crime of treason. The case was elevated to the
Tribunal for mandatory review, for judgments of the lower courts imposing death penalties.
ISSUE:
Whether or not his denials and defense of duress exerted by the Japanese Imperial Army upon him will suffice to
exempt him from the crime of treason?
RULING:
The Court ruled that mere denial by appellant cannot prevail upon the positive assertion and corroboration of the
statements of witnesses for the government establishing incriminating facts. It is a well settled rule of evidence that
as between positive and negative testimony, the former deserves more weight and credit. With regards to his
defense of duress allegedly exerted by the Japanese upon him for which he had to serve in the Detective Force of
the Japanese Army, the defendant was not able to present sufficient proof that he was indeed coerced or compelled
by the Japanese but merely stated self-serving testimonies. Duress, force, fear or intimidation to be available as a
defense, the fear must be well-founded, an immediate and actual danger of death or great bodily harm must be
present and the compulsion must be of such a character as to leave no opportunity to accused for escape or selfdefense in equal combat. A threat of future injury is not enough.
Hence, the decision of the lower court was affirmed with modifications on the indemnities imposed and that the
penalty of death be commuted to reclusion perpetua due to lack of sufficient votes to impose the justifiable penalty
of death.
-------- ======== // ========--------

1|C r i m i n a l L a w I I C a s e D i g e s t s 2

n d

Semester A/Y 2014-2015 by: J.A. Buenaventura