Goku Died On Planet Namek
If you are not paying close enough attention, the anime’s addition of filler material into the surrounding incidents makes this one a little more confusing than it should be.
In chapters 322 and 323, a newly-Super Saiyan Goku is fighting against a final-form Freeza. Goku launches a Kamehameha against his foe, who proceeds to fly into it and eventually bust right through, knocking Goku down underground. At the very same time, back on Earth, Mr. Popo has summoned Shenlong and proceeds to wish all those killed by Freeza back to life. Freeza laughs to himself with pride, but looks around wondering what is going on with the sky. We see the murdered Namekians begin to stand up (having been wished back to life), and much to Freeza’s surprise, a very exhausted-looking Super Saiyan Goku rises up out of the ocean like a phoenix from its own ashes.
So wait: did Goku just get wished back to life…?!?
It is impossible for that wish to have brought Goku back to life. Prior to Dende’s power-up, Shenlong is unable to bring the same person back to life more than once, even as part of another wish. Since Shenlong brought Goku back to life during the previous story arc on Earth (right before the battle with Nappa & Vegeta), Goku therefore could not have been dead and revived in this instance.
The anime (Dragon Ball Z episode 100) does not help the situation, adding in additional filler material where Gohan drones on and on about how he can no longer feel his father’s ki, and proceeds to fly back to battle with Freeza.
Just as in the manga, Goku rises up out of the ocean after the wish is made, but the fact still remains that Shenlong could not have brought Goku back to life for a second time at this point in the story.