**Facts:**
– **Criminal Charges**: Norberto Jimenez and Loreto Barrioquinto were charged with murder. Barrioquinto had not been arrested, so only Jimenez was tried. The Court of First Instance of Zamboanga sentenced Jimenez to life imprisonment.
– **Amnesty Proclamation**: Before his appeal period expired, Jimenez became aware of Proclamation No. 8 (September 7, 1946), granting amnesty for acts in resistance to Japanese forces during World War II. Both Jimenez and apprehended Barrioquinto applied for amnesty to the 14th Guerrilla Amnesty Commission, presided over by the respondents.
– **Commission Hearing**: On January 9, 1947, the Commission returned their cases to the Court of First Instance without deciding if they were entitled to amnesty. The basis for this refusal was that neither Jimenez nor Barrioquinto admitted committing the offense. Barrioquinto stated that Hippolito Tolentino shot the victim.
– **Petition for Mandamus**: Petitioners sought a mandamus to compel the Commission to decide on their amnesty.
**Issues:**
1. **Requisite for Amnesty**: Whether admitting guilt is a necessary condition for claiming the benefits of amnesty under Proclamation No. 8.
2. **Obligations of Amnesty Commissions**: Whether the Amnesty Commission was required to investigate and decide on the merits of the amnesty applications despite denials by petitioners of committing the criminal act.
3. **Nature of Evidence**: Whether respondents were justified in refusing to grant amnesty based on petitioners’ denial of the criminal act alleged.
**Court’s Decision:**
– **Non-necessity of Admission of Guilt**: The Supreme Court emphasized that amnesty, unlike pardon, is a public act of which courts must take judicial notice. Amnesty does not require an admission of guilt from the accused. Rather, it looks backward to obliterate the offense, effectively rendering the individual as never having committed the crime as per the legal standpoint.
– **Amnesty Commission’s Role**: The Commission must investigate whether the facts of the case fall within the terms of the proclamation. This includes analyzing evidence from both the complainant and the defendant. The denial by the accused of committing the crime does not exempt the Commission from conducting hearings and making determinations on the merits.
– **Evidence Assessment**: The Supreme Court held that the Commission had wrongly equated non-admission of guilt with ineligibility for amnesty. The proclamation’s intent was for participants of resistance against Japanese occupiers to be recognized and pardoned for their actions, even if they deny certain aspects of the charges against them.
**Doctrine:**
The Supreme Court established that for eligibility under an amnesty proclamation, there is no prerequisite for the accused to admit committing the offense. The decisive criterion is whether evidence shows the offense was committed in furtherance of resistance against the enemy within the mandate of the amnesty proclamation.
**Class Notes:**
– **Amnesty**: (1) Public act taken judicial notice of by courts; (2) Granted to classes of persons for political offenses.
– **Pardon vs. Amnesty**: (1) Pardon is a private act; (2) Amnesty obliterates the offense as if it was never committed.
– **Elements for Applying Amnesty**: (1) The act must fall under the specified period and purpose (resistance to the enemy); (2) Courts must evaluate circumstances, even if the accused denies committing the crime.
– **Relevant Statute**: Proclamation No. 8 (Sept 7, 1946)
**Historical Background:**
Post-WWII, the Philippines had instances of patriots engaging in guerilla resistance against Japanese forces. Following liberation, these acts, though criminal under regular statutes, were recognized as patriotic. President Manuel Roxas’ Proclamation No. 8 aimed to grant amnesty to such individuals to recognize their contributions and relieve their criminal liabilities, promoting national healing and reconciliation. Cases like Barrioquinto and Jimenez’s underscore the legal complexity of transitioning from war to peace, balancing justice with gratitude for wartime sacrifices.
Leave a Reply