G.R. No. L-1260, December 31, 1903
THE UNITED STATES, complainant-appellee, vs. FRANCISCO DAVID, ET AL., defendants-appellants.

FACTS:
The appellant, Francisco David, was convicted of the crime of assassination and sentenced to life imprisonment. The crime occurred in Surigao sometime in 1900, during the Philippine-American War. The evidence showed that David, a revolutionary soldier in uniform, and his companions seized an American named French because he was an American. They initially intended to take him to their commander, Daniel T. Sisson. Upon meeting another revolutionary, Francisco Villabrille, custody of the prisoner was given to David with instructions to take him to Sisson. However, David killed French with a bolo while en route. The complaint was only filed in February 1903. The lower court convicted David and held that he was not entitled to the benefits of the amnesty proclaimed on July 4, 1902.

ISSUE:
Whether or not the appellant, Francisco David, is entitled to the benefits of the amnesty proclamation of July 4, 1902.

RULING:
Yes. The Supreme Court reversed the lower court’s decision and held that David was entitled to amnesty.
The Court found that: (1) David was a participant in the insurrection against the United States at the time of the offense; (2) the crime was political in character, as the arrest and subsequent killing of French were solely because he was an American and an enemy in the context of the war; and (3) the evidence sufficiently showed that David committed the act pursuant to the orders of his superior, Francisco Villabrille. The killing was directly connected to the insurrection. Therefore, the crime fell within the scope of the amnesty proclamation. The Court ordered that upon David’s filing of the required oath, the case against him would be dismissed.
Note: Justice Johnson dissented, arguing that the proof did not show David or his crime were included in the amnesty proclamation.