GR 1014; (May, 1903) (Digest)
G.R. No. 1014 , May 9, 1903
THE UNITED STATES, complainant-appellee, vs. MANUEL REPOLLO ET AL., defendants-appellants.
FACTS:
The defendants, Manuel Repollo, Candido Repollo, Bruno Dolor, and Florencio Nicolas, were convicted by the Court of First Instance of Pangasinan for the murder of Basilio Limon in November 1899 and each sentenced to death. On appeal, the defendants filed a motion for a new trial, invoking the amnesty proclamation issued by the President of the United States on July 4, 1902. In support, they submitted affidavits stating that at the time of the killing, they were members of the Katipunan government and acted under orders of their superiors, Francisco Cabe and Insiong Prado, who accused Limon of being an American spy. The affidavits claimed that Cabe and Prado alone killed Limon after ordering the defendants to leave. At the original trial, the defendants had denied involvement and presented alibi defenses. The prosecution evidence showed that the defendants forcibly took Limon from his house, and his decapitated body was later found nearby.
ISSUE:
Whether a new trial should be granted to allow the defendants to present evidence that the killing was politically motivated and thus covered by the amnesty proclamation.
RULING:
Yes, the Supreme Court granted a new trial. The Court held that while the affidavits did not constitute “newly discovered evidence” in the traditional sense, they became material due to the subsequent amnesty proclamation, which provided a potential defense not available at the time of trial. The Court found that justice required granting a new trial under the spirit of Section 42 of General Orders No. 58, to allow the defendants an opportunity to prove their claim that the offense was politically motivated and fell within the amnesty. The judgment was set aside, and the case remanded to the Court of First Instance for a new trial. Costs were adjudged de oficio.
Dissenting Opinion:
Justice Willard, with Justice Arellano concurring, dissented, arguing that the motion was based solely on newly discovered evidence, which the affidavits did not constitute, as the defendants knew the facts at the time of trial but had previously denied participation.