People vs. Manayao, G.R. No. L-322 – Case Digest

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On January 29, 1945, Japanese soldiers and a number of Filipinos affiliated with the Makapili, including the appellant, gathered the residents of barrio Banaban of Angat, Province of Bulacan. In accordance with their plan, they killed the residents excluding the children. The appellant alone killed about six women and would have also killed the children if he had been allowed to. 

The appellant was then convicted with the high crime of treason with multiple murder in the People’s Court.

In his appeal, his counsel contends that he is a member of the Armed Forces of Japan and is therefore not subject to the jurisdiction of the People’s Court. He also contends that the appellant has already lost his Filipino citizenship thus he is not amenable to the Philippine law of treason.


Whether or not the appellant has lost his citizenship by being a member of Makapili thus making him not guilty of the crime of treason.


No. The appellant did not lose his Filipino citizenship.

His oath as a Makapili member that he will help Japan in its fight against Americans does not equate to an oath of allegiance to the support the constitution or laws of Japan. There is also no evidence that he accepted a commission “in the military, naval, or air service” of Japan. He was only a member of Makapili, a group which although organized to render aid to the Japanese army, was not part of the Japanese army.

Moreover, if his commission of treasonous acts will divest him of his Philippine citizenship, then  his very crime would be the shield that would protect him from punishment.