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Title One Q: Is it necessary under this mode that the purpose

CRIMES AGAINST NATIONAL SECURITY AND THE of levying war is to deliver the country in whole or in
LAW OF NATIONS part to the enemy?
A: Yes, if the uprising is committed without enemy
Section One. Treason and espionage collaboration, the crime would be rebellion not
Article 114. Treason treason.
Article 115. Conspiracy and proposal to commit treason
Article 116. Misprision of treason
Article 117. Espionage
2nd mode: “Adhering to the enemies, giving
them aid or comfort”
Section Two. Provoking war and disloyalty in case of war
Article 118. Inciting to war or giving motives for “Adherence to the enemy” means intent to betray.
reprisals There is “adherence to the enemy” when a citizen
Article 119. Violation of neutrality intellectually or emotionally favors the enemy and
Article 120. Correspondence with hostile country harbors sympathies or convictions disloyal to his
Article 121. Flight to enemy’s country country’s policy or interest.
Section Three. Piracy and mutiny on the high seas in
Philippine waters “Aid or comfort” means an act which strengthens or
Article 122. Piracy in general and mutiny on the high tends to strengthen the enemy in the conduct of war
seas or in Philippine waters against the traitor’s country and an act which
Article 123. Qualified piracy weakens or tends to weaken the power of the traitor’s
country to resist or to attack the enemy.

Article 114. Treason Adherence alone, without giving aid or comfort, does
NOT constitute treason.
Elements:
The aid and comfort must be a deed or physical
1. Offender is a Filipino citizen or an alien activity. To be treasonous, the extent of aid and
residing in the Philippines; comfort must be to render assistance to them as
2. There is a war in which the Philippines is enemies and not merely as individuals, and be directly
involved; in furtherance of the enemies’ hostile designs .
3. The offender either – However, the act need not actually strengthen the
a. Levies war against the Government; enemy.
or
b. Adheres to the enemies, giving The aid or comfort under this mode must be after the
them aid or comfort. declaration of war. The enemies must be subject of a
foreign power.
 Treason cannot be committed in time of
peace. When killings and other common crimes are charged
as overt acts of treason, they cannot be regarded as
1st mode: “Levying war against the separate crimes or complexed with treason.
Government”
Example: Where the accused served as
There must be an actual assembling of men. Thus, secret agent for the Japanese, and in the
the actual enlistment of men to serve against the performance of such service, he participated
government doesn’t amount to levying war. in the Japanese expeditions against guerillas
and committed mass murders, arson and
Under this mode, it is not necessary that there be a robberies, and those deeds were charged an
formal declaration of the existence of a state of war. element of treason, they become identified
Actual hostilities may determine the date of the with the crime of treason and cannot be the
commencement of war. subject of a separate punishment.

The war must be directed against the government, But this rule will not preclude the punishment of
not merely to resist a particular statute or to repel a common crimes as such, IF the prosecution should
particular officer. However, it is NOT necessary that elect to prosecute the culprit specifically for those
those attempting to overthrow the gov’t succeed in crimes, instead of relying on them as an element of
their designs. treason.

Ways of proving treason

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A person may be convicted of treason on the designs. Sexual relations between the women and the
following evidence ONLY: Japanese officials cannot be said to aid in the furtherance
of the objectives of the enemies.
1. [Two-witness rule] Testimony of two
witnesses, at least, to the same overt act; or Dissent by Pablo: Entertainment tones up the nerves of the
2. Confession of the accused in open court. soldiers. Services or favors that should have been
performed by Japanese women were done by Filipino
The two-witness rule women. This helped improve the phases of their military
activities.
The testimony of two witnesses is required to prove
the overt act of giving aid or comfort. It is not People vs. Prieto
necessary to prove adherence.
Prieto, a Makapili who aided the Japanese in apprehending
Q: A testified that he saw X on guard duty in the Filipino guerillas (who were tortured and executed after
Japanese garrison on Monday. B testified that he also being apprehended) was convicted of 4 counts of treason.
saw X on guard duty in the garrison on Wednesday.
HELD: Murder and physical injuries are identified as an
Can X be convicted of treason on the basis of A & B’s element of treason and they cannot be the subject of a
testimony? separate punishment, or make a complex crime with
A: No. Both overt acts, although of the same nature treason. They are averred as a constitutive ingredient of
and character, are two distinct acts. Either one, to treason. But where the State prosecutes them for such acts
serve as a ground for conviction, must be proved by not as an overt act for treason, then the accused can be
punished for such acts if found guilty.
two witnesses. That one witness should testify as to
one, and another as to the other, was held not
enough. People vs. Manayao

Manayao et al were charged and found guilty of treason


Laurel v. Misa with multiple murders. They were sentenced to death and
to pay the fine with indemnity to heirs of the victims of the
Petition for habeas corpus by Laurel based on the theory town they massacred with the Japanese troops. The
that a Filipino citizen who adhered to the enemy giving the massacre was witnessed by the two children spared from
latter aid and comfort during the Japanese occupation the killing.
cannot be prosecuted for the crime of treason because (1)
of the suspension of the sovereignty of the legitimate HELD: The Makapili is not part of the Japanese Army in the
government in the Philippines resulting in the suspension of Philippines being an organization of ‘traitors, pure and
the correlative allegiance of Filipinos thereto, and (2) of simple.’ This doesn’t divest the People’s Court of
the changes of sovereignty upon the proclamation of the jurisdiction. They have not lost their citizenship when no
Philippine Republic. evidence that he has subscribed to an oath of allegiance to
support the laws of Japan and that he showed his
HELD: Citizen owes absolute/permanent allegiance to his acceptance of a commission in the Armed Forces of Japan
government/sovereign, which should not be confused with were presented. They are still subject of the law on
the qualified/temporary allegiance which a foreigner owes treason in the Philippines.
to the government of his current residence. This absolute
allegiance is not abrogated by enemy occupation because
the sovereignty of the government de jure is not People vs. Adriano
transferred thereby to the occupier, remaining vested in
the legitimate government. What may be suspended is the Adriano was found guilty of treason by virtue of his being a
exercise of the rights of sovereignty passing temporarily to Makapili. The prosecution however did not introduce any
the occupant, and not the allegiance which subsists with other evidence except for his membership. Furthermore,
the subsistence of the sovereignty of the legitimate the alleged acts committed by the accused were not
government. established or concurred by testimonies from 2 witnesses.

The change in government from commonwealth does not HELD: The two-witness requirement in the crime of treason
affect the crime of treason. It holds applicable to the should be applied restrictively – the lawmakers having
present government being an offense against the same intended for it to be applied with the same rigidity and
government and sovereign people. inflexibility due to the seriousness of the crime and the
abnormality of the times from American origin.

People vs. Perez Hilado dissenting: Being a Makapili was one single
continuous and indivisible overt act of giving aid to the
Perez was convicted of treason and sentenced to death Japanese invaders. There is no need for at least 2
where 5 of the 7 counts against him alleged his abduction witnesses to have testified on one same act.
of girls for the purpose of using them to satisfy the sexual
desires of Japanese officials.

HELD: For an act to be treasonous, it should be one that


renders assistance to the occupants to further their hostile

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3. His purpose is to obtain information, plans,
Article 115. Conspiracy and proposal to commit photographs or other data of a confidential
treason nature relative to the defense of the Philippines

Elements (Conspiracy):  It is not necessary that information be actually


obtained.
1. In time of war
2. Two or more persons come to an agreement (Mode 2) Elements:
to levy war against the gov’t or to adhere to the
enemies and to give them aid or comfort; and 1. Offender is a public officer
3. They decide to commit it. 2. He has in his possession (by reason of the public
office he holds) any information, plans,
Elements (Proposal): photographs or other data of a confidential
nature relative to the defense of the Philippines
1. In time of war 3. He discloses their contents to a representative of
2. A person who has decided to levy war a foreign nation
against the gov’t or to adhere to the enemies and
to give them aid or comfort, Espionage Treason
3. Proposes its execution to some other person Both not conditioned by the citizenship of the offender
or persons. May be committed in time of Committed only in time of
peace or war war
 The two-witness rule does not apply to conspiracy Many ways of committing Only two ways of committing
espionage, taking RPC117 treason
or proposal to commit treason.
and CA616 together

Article 116. Misprision of treason


Article 118. Inciting to war or giving motives
for reprisals.
Elements:
Elements:
1. Offender must be owing allegiance to the
Government, and not a foreigner
1. Offender performs unlawful or unauthorized acts
2. He has knowledge of any conspiracy (to commit
2. Such acts provoke or give occasion for a war
treason) against the Government
involving or liable to involve the Philippines or
3. He conceals or doesn’t disclose and make known
expose Filipino citizens to reprisals on their
the same as soon as possible to the governor or
persons or property
fiscal of the province or the mayor or fiscal of the
city in which he resides.
Illustration: The public destruction of the flag or seal
of a foreign state or the public manifestations of
 A116 will not apply when the crime of treason has
hostility to the head or ambassador of another state.
already been committed by someone and the accused
doesn’t report its commission to the proper authority.
The law says “knowledge of any conspiracy against”
Article 119. Violation of neutrality
not knowledge of treason actually committed.
 The offender in misprision is punished “as an
Elements:
accessory to the crime of treason”. Hence, the
penalty for misprision is two degrees lower than that
1. There is a war in which the Philippines is no
provided for treason.
involved
2. There is a regulation issued by competent
authority for the purpose of enforcing neutrality
Article 117. Espionage
3. The offender violates such regulation
Two ways of committing espionage
Article 120. Correspondence with hostile
country
(Mode 1) Elements:
Elements:
1. Offender enters a warship, fort or naval or
military establishment or reservation
1. In time of war in which the Philippines is involved
2. He has no authority therefore

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2. The offender makes correspondence with an 1. The vessel is on the high seas or Philippine
enemy country or territory occupied by enemy waters;
troops 2. Offenders are neither members of its
3. The correspondence is either – complement nor passengers of the vessel;
a. Prohibited by the Government, or 3. Offenders either -
b. Carried on in ciphers or a. attack or seize a vessel on the high seas or
conventional signs, or in Philippine waters; or
c. Containing notice or information b. seize in the vessel while on the high seas or
which might be useful to the enemy. in Philippine waters the whole or part of its
cargo, its equipment or personal belongings
 “Correspondence” means communications by means of its complement or passengers;
of letters. 4. There is intent to gain.

 Even if the correspondence contains innocent  “Piracy” is robbery or forcible depredation on the
matters, if the correspondence has been prohibited by high seas, without lawful authority and done with
the Government, it is punishable. animo furandi and in the spirit and intention of
 Prohibition by the Government is not essential in universal hostility.
paragraphs 2 & 3 of Article 120.
Piracy Robbery on the high seas
 Circumstances qualifying the offense: Offender is an outsider The offender is a member of
1. Notice or information might be useful to the the complement or a
enemy; AND passenger of the vessel
Manner of committing the crime is the same
2. Offender intended to aid to enemy
There is intent to gain
 These acts amount to treason. Hence, the penalty
is the same as that for treason.
Piracy Mutiny
Persons who attack a vessel Offenders are members of
or seize its cargo are the crew of passengers
Article 121. Flight to Enemy's Country
strangers to said vessels
Intent to gain essential Intent to gain not essential,
Elements: offenders may only intend to
ignore the ship’s officer’s
1. There is a war in which the Philippines is
involved; PRESIDENTIAL DECREE No. 532
2. Offender must be owing allegiance to the ANTI-PIRACY AND ANTI-HIGHWAY ROBBERY LAW
government; OF 1974
3. Offender attempts to flee or go to enemy Definition of Terms
country;
4. Going to the enemy country is prohibited by a. Philippine Waters. It shall refer to all bodies of water, such
competent authority. as but not limited to, seas, gulfs, bays around, between and
connecting each of the Islands of the Philippine Archipelago,
 Mere attempt to flee or go to enemy country irrespective of its depth, breadth, length or dimension, and
all other waters belonging to the Philippines by historic or
consummates the crime.
legal title, including territorial sea, the sea-bed, the insular
shelves, and other submarine areas over which the
Philippines has sovereignty or jurisdiction.
Article 122. Piracy in general and Mutiny on
the High Seas or in Philippine Waters
b. Vessel. Any vessel or watercraft used for transport of
passengers and cargo from one place to another through
Acts punished as piracy Philippine Waters. It shall include all kinds and types of
vessels or boats used in fishing.
1. Attacking or seizing a vessel on the high
seas or in Philippine waters; c. Philippine Highway. It shall refer to any road, street,
2. Seizing in the vessel while on the high seas passage, highway and bridges or other parts thereof, or
or in Philippine waters the whole or part of its railway or railroad within the Philippines used by persons, or
cargo, its equipment or personal belongings of its vehicles, or locomotives or trains for the movement or
complement or passengers. circulation of persons or transportation of goods, articles, or
property or both.
Elements of piracy
d. Piracy. Any attack upon or seizure of any vessel, or the
taking away of the whole or part thereof or its cargo,

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(2.5%)
SUGGESTED ANSWER:
equipment, or the personal belongings of its complement or
The crime committed is qualified piracy, because it was
passengers, irrespective of the value thereof, by means of
accompanied by physical injuries/homicide. The culprits
violence against or intimidation of persons or force upon
stabbed a member of the crew while sleeping (Art. 123,
things, committed by any person, including a passenger or
Revised Penal Code).
member of the complement of said vessel, in Philippine
Highway Robbery (2001)
waters, shall be considered as piracy. The offenders shall be
Police Sgt. Diego Chan, being a member of the Theft and
considered as pirates and punished as hereinafter provided.
Robbery Division of the Western Police District and assigned
to the South Harbor, Manila, was privy to and more or less
e. Highway Robbery/Brigandage. The seizure of any person familiar with the schedules, routes and hours of the
for ransom, extortion or other unlawful purposes, or the movements of container vans, as well as the mobile police
taking away of the property of another by means of violence patrols, from the pier area to the different export processing
against or intimidation of person or force upon things of zones outside Metro Manila. From time to time, he gave
other unlawful means, committed by any person on any valuable and detailed information on these matters to a
Philippine Highway. group interested in those shipments in said container vans.
On several instances, using the said information as their
Punishable Acts under the Crime of Piracy basis, the gang hijacked and pilfered the contents of the
1. Any attack upon or seizure of any vessel vans. Prior to their sale to "fences" in Banawe, Quezon City
2. The taking of the whole or part thereof or its cargo, and Bangkal, Makati City, the gang Informs Sgt, Chan who
equipment, or the personal belongings of its complement or then inspects the pilfered goods, makes his choice of the
passengers, irrespective of the value therefore valuable items and disposes of them through his own
3. That the above acts were done by means of violence sources or "fences". When the highjackers were traced on
against or intimidation of persons or force upon things. one occasion and arrested,
upon custodial investigation, they implicated Sgt. Chan and
Punishable Acts under the Crime of Highway the fiscal charged them all, including Sgt. Chan as co-
Robbery/Brigandage principals. Sgt. Chan, in his defense, claimed that he should
1. Any attack upon or seizure on any highway not be charged as a principal but only as an accessory after
2. The taking of the whole or part thereof or its cargo, the fact under P.D. 532, otherwise known as the Anti-Piracy
equipment, or the personal belongings of its complement or and Anti-Highway Robbery Act of 1972. Is the contention of
passengers, irrespective of the value therefore Sgt. Chan valid and tenable? Explain, (5%)
3. That the above acts were done by means of violence SUGGESTED ANSWER:
against or intimidation of persons or force upon things. No, the contention of Sgt. Chan is not valid or tenable
because by express provision of P.D. 532, Section 4, a
Acts Punishable: person who knowingly and in any manner, aids or protects
AIDING OR ABETTING PIRACY REQUISITES: highway robbers/brigands, such as giving them information
1. Knowingly aids or protects pirates; about the movement of police officers or acquires or receives
2. Acquires or receives property taken by such pirates, or in property taken by brigands, or who directly or indirectly
any manner derives any benefit; abets the commission of highway robbery/brigandage, shall
3. Directly or indirectly abets the commission of piracy be considered as accomplice of the principal offenders and
punished in accordance with the rules in the Revised Penal
Code.
BAR QUESTIONS ALTERNATIVE ANSWER:
Piracy in the High Seas & Qualified Piracy
No, the contention of Sgt. Chan that he should be charged
Nagoya Maru was negotiating the sea route from Hongkong only as accessory after the fact is not tenable because he
towards Manila, and while still 300 miles from Aparri,
was a principal participant in the commission of the crime
Cagayan, its engines malfunctioned. The Captain ordered the and in pursuing the criminal design. An accessory after the
ship to stop for emergency repairs lasting for almost 15
fact involves himself in the commission of a crime only after
hours. Due to exhaustion, the officers and crew fell asleep. the crime had already been consummated, not before, For
While the ship was anchored, a motorboat manned by
his criminal participation in the execution of the highjacking
renegade Ybanags from Claveria, Cagayan, passed by and of the container vans, Sgt. Chan is a co-principal by
took advantage of the situation. They cut the ship's engines
indispensable cooperation.
and took away several heavy crates of electrical equipment
and loaded them in their motorboat. Then they left hurriedly
People vs. Lol-lo and Saraw
towards Aparri. At daybreak, the crew found that a robbery
took place. They radioed the Aparri Port Authorities resulting
Boat carrying men, women and children on its way between
in the apprehension of the culprits.
two islands in the Dutch East Indies were waylaid by six
What crime was committed? Explain. (2.5%) vintas manned by 24 armed Moros. At first, they asked for
SUGGESTED ANSWER: good but one on the Dutch boat, they took all of the cargo,
Piracy in the high seas was committed by the renegade attacked some of the men and brutally violated two of the
Ybanags. The culprits, who are neither members of the women. All the people were placed back into the boat
complement nor passengers of the ship, seized part of the except the two men, and holes were made with the idea of
equipment of the vessel while it was three hundred miles submerging the boat. They took the women and repeatedly
away from Aparri, Cagayan (Art. 122, Revised Penal Code). violated them. Two of the raiders were Lol-lo and Saraw,
Supposing that while the robbery was taking place, the former participating in the rape. The women eventually
the culprits stabbed a member of the crew while escaped while Saraw and Lol-lo returned to TawiTawi
sleeping. What crime was committed? Explain.

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where they were apprehended and tried. They were found c. whenever the crime is accompanied by
guilty and sentenced to life imprisonment. murder, homicide, physical injuries or rape.
HELD: Pirates are in the law hostes humani generis. Piracy
is a crime not against any particular state but against all R.A. 6235
mankind. It may be punished in the competent tribunal of An Act Prohibiting Certain Acts Inimical to Civil
any country where the offender may be found or into which Aviation
he may be carried. The jurisdiction in the crime of piracy
unlike other crimes has no territorial limits, nor does it Who are punishable?
matter that a crime was committed within the
jurisdictional 3-mile limit of a foreign state, “for those 1. Any person who shall compel a change in the course or
limits, through neutral to war, are not neutral to crimes.” destination of an aircraft of Philippine registry, or to
seize or usurp the control thereof, while it is in flight.
People vs. Rodriguez An aircraft is in flight from the moment all its external
doors are closed following embarkation until any of
Rodriguez et al (crew members of M/V Noria 767) were
such doors is opened for disembarkation. (§1)
charged with the crime of piracy, found guilty and
sentenced to death. They were able to obtain 3M as total
2. Any person who shall compel an aircraft of foreign
amount and escaped through the use of pump-boats. Ten
dead bodies were seen at the wharf as victims of the sea- registry to land in Philippine territory or to seize or
jacking usurp the control thereof while it is within the said
territory. (§1)
HELD: Where rape, murder or homicide is committed in the
crime of piracy, the penalty imposable is mandatory death The penalty shall be increased whenever the violations
penalty according to PD532 amending RPA 134. above were committed under any of the following
circumstances:

People vs. Siyoh  Whenever he has fired upon the pilot, member of
the crew or passenger of the aircraft;
Siyoh et al were accused of qualified piracy with triple  Whenever he has exploded or attempted to
murder and frustrated murder, found guilty and sentenced explode any bomb or explosive to destroy the
to death. With the use of pump-boats, they were able to aircraft; or
divest money and goods from de Guzman and his  Whenever the crime is accompanied by murder,
companions on the way to Mataja island. The companions homicide, serious physical injuries or rape. (§2)
were killed while de Guzman was able to escape wounded.
3. Any person, natural or juridical, who shall ship, load or
HELD: Although the body of de Guzman was still missing, carry in any passenger aircraft operating as a public
the number of persons killed on the occasion of piracy is utility within the Philippines, any explosive, flammable,
not material. PD532 considers qualified piracy (when rape, corrosive or poisonous substance or material. (§3)
murder, or homicide is committed as a result or on the
occasion of piracy) as a special complex crime punishable
“Explosive” - any substance, either solid or liquid,
by death regardless of the number of victims.
mixture or single compound, which by chemical
reaction liberates heat and gas at high speed and
causes tremendous pressure resulting in explosion. The
Article 123. Qualified Piracy term shall include but not limited to dynamites,
firecrackers, blasting caps, black powders, bursters,
Elements: percussions, cartridges and other explosive materials,
except bullets for firearm.
1. The vessel is on the high seas or Philippine
"Flammable" – any substance or material that is
waters:
highly combustible and self-igniting by chemical
2. Offenders may or may not be members of its reaction and shall include but not limited to acrolein,
complement, or passengers of the vessel; allene, aluminum dyethyl monochloride, and other
3. Offenders either - aluminum compounds, ammonium chlorate and other
a. attack or seize the vessel; or ammonium mixtures and other similar substances or
b. seize the whole or part of the cargo, its materials.
equipment., or personal belongings of the
crew or passengers; "Corrosive" – any substance or material, either liquid,
solid or gaseous, which through chemical reaction
4. The preceding were committed under any of
wears away, impairs or consumes any object. It shall
the following circumstances: include but not limited to alkaline battery fluid packed
a. whenever they have seized a vessel by with empty storage battery, allyl chloroformate,
boarding or firing upon the same; allytrichlorosilane, ammonium dinitro-orthocresolate
b. whenever the pirates have abandoned their and other similar materials and substances.
victims without means of saving themselves;
or "Poisonous" – any substance or materials, except

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medicinal drug, either liquid, solid or gaseous, which thereby sowing and creating a condition of widespread and
through chemical reactions kills, injures or impairs a extraordinary fear and panic among the populace, in order to
living organism or person, and shall include but not coerce the government to give in to an unlawful demand”
limited to allyl isothiocyanate, ammunition (chemical,
non-explosive but containing Class A, B or poison), Requirements for Terrorism
aniline oil, arsine, bromobenzyle cyanide,
bromoacetone and other similar substances or A. The accused ( maybe a single individual or a group)
materials. must commit any of the enumerated crimes

For any death or injury to persons or damage to property B. There results a condition of widespread and
resulting from a violation of §3 above, the person extraordinary fear and panic among the populace
responsible therefor may be held liable in accordance with i. The extent and degree of fear and panic,
the applicable provisions of the Revised Penal Code. including the number of people affected in order
to meet the term “populace”, are questions of
facts to be determined by the courts and on a
Authority of airline companies to inspect cargo etc. case to case basis.
ii. Is the term “populace’ to be interpreted as
Aircraft companies which operate as public utilities referring to the local inhabitants where the acts
or operators of aircraft which are for hire are authorized to were committed, or does it refer to the national
open and investigate suspicious packages and cargoes in the population?
presence of the owner or shipper, or his authorized
representatives if present; in order to help the authorities in C. The purpose of the accused must be to coerce the
the enforcement of the provisions of this law government to give into an unlawful demand
i. The word “demand” is too broad as to cover
If the owner, shipper or his representative refuses not only political, criminal or monetarial
to have the same opened and inspected, the airline or air demands but also those which maybe
carrier is authorized to refuse the loading thereof. (§8) categorized as social or economic. This however
is qualified by the word “ unlawful”.

Disclaimer on airline ticket

Every ticket issued to a passenger by the airline or


air carrier concerned shall contain among others the
following condition printed thereon: "Holder hereof and his
hand-carried luggage(s) are subject to search for, and
seizure of, prohibited materials or substances. Holder
refusing to be searched shall not be allowed to board the
aircraft," which shall constitute a part of the contract
between the passenger and the air carrier. (§9)

REPUBLIC ACT NO. 9372


AN ACT TO SECURE THE STATE AND PROTECT OUR
PEOPLE FROM TERRORISM
Defines the crime of terrorism to be the commission of “any
of the crimes of :

A. Under the Revised Penal Code.


i. Piracy in general and Mutiny in the High Seas or in
the Philippine Waters
ii. rebellion
iii. Coup d’etat
iv. Murder
v. Kidnapping and Serious Illegal Detention

B. Under Special Laws


i. Arson under P.D. 1613
ii. Violation of R.A. 6969 ( Toxic Substance ad
Nuclear Waste Control)
iii. R.A. 5207 ( Atomic Energy Regulatory and
Liability Act of 1968)
iv. Hijacking
v. Piracy in Phil. Waters and Highway Robbery
vi. P.D. 1866 ( Possession and Manufacture of
Firearms/explosives)

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