People vs. Manayao
FACTS: The three accused were charged with treason complexed with multiple murder in the People’s Court. They participated in the massacre of several citizens who were suspected to have been helping the guerillas. The accused claimed that they cannot be tried since the Court has no jurisdiction. Furthermore, they claimed that they had renounced their Filipino citizenship after joining the Japanese paramilitary Makapili, and then swearing allegiance to Japan.
HELD/RATIO: The accused were found guilty. The Makapili is not a part of the Japanese army. It was an organization of Filipino traitors. Moreover, there is no evidence that the accused swore to an oath of allegiance when they entered the said organization. Furthermore, it is the lone prerogative of the State to allow or deny one’s change of citizenship.
