GR 1015; (May, 1903) (Digest)

G.R. No. 1015, May 14, 1903
THE UNITED STATES, complainant-appellee, vs. CANDIDO REPOLLO, ET AL., defendants-appellants.

FACTS:
The defendants, Candido Repollo, Manuel Repollo, Julian Repollo, and Bruno Dolor, were convicted and sentenced to death for the murder of Proceso Vallesteros on the night of May 16, 1902. After the case was appealed, the defendants filed a motion for a new trial based on the Amnesty Proclamation issued by the President of the United States on July 4, 1902. In support of their motion, they submitted affidavits stating that at the time of the killing, they were members of the Katipunan and acted under the orders of Agustin Alejo, a captain of the insurgent forces. According to their affidavits, Captain Alejo ordered them to seize and kill Vallesteros because he was allegedly an American spy who had revealed the location of insurgent forces. The killing was carried out by a group of soldiers and individuals under Alejo’s command. The trial record showed no personal motive for the killing, indicating it was likely politically motivated, arising from internal conflicts during the insurrection.

ISSUE:
Whether the defendants are entitled to a new trial to present evidence that the crime was of a political character and thus covered by the Amnesty Proclamation.

RULING:
Yes. The Supreme Court granted the motion for a new trial. Although the evidence presented in the affidavits was not newly discovered in the traditional sense, it became material and vital due to the subsequent issuance of the Amnesty Proclamation. The Court found a strong probability that the killing was politically motivated, stemming from the insurrection. Following its precedent in a similar case (U.S. vs. Manuel Repollo, et al.), the Court set aside the judgment and remanded the case to the Court of First Instance for a new trial pursuant to Section 42 of General Orders, No. 58. Costs were adjudged de oficio.