### **Facts:**
1. **Background:**
– Petition involving Ramon Ruffy, Prudente M. Francisco, Dominador Adeva, Andres Fortus, Jose L. Garcia, and Victoriano Dinglasan, who had varied affiliations with the Philippine Army, Philippine Constabulary, and guerilla organizations.
– At the Philippine-American war’s outbreak on December 8, 1941, Major Ramon Ruffy was the Provincial Commander of the Philippine Constabulary in Mindoro. Officers included Prudente M. Francisco (junior officer) and Andres Fortus (Corporal).
– On February 27, 1942, the Japanese forces landed in Mindoro. Major Ruffy retreated to the mountains, organizing the “Bolo Combat Team” guerilla group.
2. **Integration into 6th Military District:**
– Brigadier-General Macario Peralta, Jr., leading the 6th Military District, extended operational control over Mindoro and Marinduque and designated Major Ruffy as Acting Commander for those provinces.
– Several members, including Francisco and Fortus, accepted military appointments, thus integrating into the recognized military unit under the operational control of General MacArthur’s command.
3. **Alleged Crime:**
– The petitioners were accused of murdering Lieut. Col. Enrique L. Jurado on October 19, 1944.
– After this incident, they allegedly seceded from the 6th Military District.
4. **Procedural Posture:**
– Initial petition for prohibition and preliminary injunction filed to stop trial by the General Court-Martial.
– Court-Martial proceeded: Ruffy was acquitted, Dinglasan’s case was dismissed, but Garcia, Francisco, Adeva, and Fortus were convicted.
– New petition for certiorari submitted to the Supreme Court challenging their subjectivity to military law and the constitutionality of the 93rd Article of War.
### **Issues:**
1. **Applicability of Military Law:**
– Whether the petitioners were subject to military law during the commission of the alleged offense.
2. **Constitutionality of the 93rd Article of War:**
– Whether the 93rd Article of War is unconstitutional for not providing Supreme Court review of sentences of death or life imprisonment as per Article VIII, section 2, paragraph 4 of the Philippine Constitution.
### **Court’s Decision:**
**1. Applicability of Military Law:**
– **Participation in the Philippine Army:**
– The Supreme Court held that the petitioners, by accepting appointments within the Bolo Combat Team, which was recognized as part of the Philippine Army under the 6th Military District, were subject to military law.
– Articles of War encompass individuals lawfully inducted or called to military service.
– The guerilla activities, under the Southwest Pacific Command with supplies and funds provided, maintained petitioners within the military jurisdiction.
– **Suspension of National Defense Act:**
– During enemy occupation, political laws were suspended, but military jurisdiction persisted. The guerilla units continued under military discipline reflecting continuous lawful military operations.
**2. Constitutionality of the 93rd Article of War:**
– **Nature of Courts-Martial:**
– Courts-martial, executive agencies created to maintain military discipline, operate under the President’s authority as Commander-in-Chief.
– Courts-martial decisions are not typically within judicial review per traditional distinctions outlined.
– **Supreme Court Review:**
– While the Philippine Constitution permits Supreme Court jurisdiction over certain criminal cases, court-martial sentences were transformations of long-established military justice prerogatives.
– The court did not find the 93rd Article of War unconstitutional since the courts-martial function within an executive domestic framework distinct from civil courts.
### **Doctrine:**
1. **Jurisdiction over Military Personnel:**
– Individuals inducted into recognized military units are subject to military jurisdiction regardless of the status of overarching political laws during occupation.
2. **Nature of Courts-Martial:**
– Courts-martial are executive instruments created under the President’s military authority, operating independently from the civil judiciary system.
3. **Constitutionality of Military Sentencing:**
– Sentences from courts-martial can be constitutionally distinct from the civil judiciary review process, reflecting military discipline needs.
### **Class Notes:**
1. **Elements of Military Jurisdiction:**
– Acceptance of military appointments subjects individuals to military law.
– Political suspension during occupation does not abrogate military operational status.
– Reference: Article 2 of the Articles of War.
2. **Executive Nature of Courts-Martial:**
– Courts-martial function under the executive branch, not part of the judiciary.
– Their primary role is to maintain military discipline, independent of the civil judicial review.
3. **Military Sentencing:**
– Sentences by courts-martial for offenses committed during war periods stand unless challenged for jurisdiction violation.
4. **Historical Context:**
– Post-World War II restructuring reaffirmed Guerilla units’ role that persisted under organized commands recognized by global military commands.
### **Historical Background:**
– This case emerges during post-World War II Philippines, during a time of transition and reconstitution after the Japanese occupation.
– The trial and subsequent petition reflect the ongoing integration of guerilla units into formal military structures under U.S. command, preserving order amidst restructuring for independence.
– The contentions highlight the differences between civil government structures and military necessity during wartime, especially under an occupied nation.
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