GR 1016; (January, 1903) (Digest)
G.R. No. 1016 : January 16, 1903
THE UNITED STATES, complainant-appellee, vs. CATALINO VERGARA, defendant-appellant.
FACTS:
The appellant, Catalino Vergara, was convicted of asesinato (murder) by the Court of First Instance of Pangasinan and sentenced to death. The evidence established that in March 1900, while Vergara was understood to be the president of the pueblo of Mangatarem under the Filipino revolutionary government, he either killed or caused the killing of several persons. The circumstances indicated that the victims were native Filipinos who were put to death because they favored the Americans or had rendered services to the American Army. There was no evidence that Vergara acted under orders from any superior authority. Vergara petitioned for the benefit of the amnesty granted by the President’s proclamation of July 4, 1902, and the Solicitor-General concurred with the petition.
ISSUE:
Whether the appellant is entitled to the amnesty under the President’s proclamation of July 4, 1902, for the crime of murder committed during the insurrection against the United States.
RULING:
Yes, the appellant is entitled to the amnesty. The proclamation grants amnesty for: (1) purely political crimes (treason and sedition); (2) common crimes political in character if committed pursuant to orders from superior authority; and (3) crimes that grew out of “internal political feuds or dissensions between Filipinos and Spaniards or the Spanish authorities, or which resulted from internal political feuds or dissensions among the Filipinos themselves” during the insurrections.
The Court held that the present case falls under the third category. The phrase “internal political feuds or dissensions among the Filipinos themselves” includes the significant political division between Filipinos who resisted and those who supported the United States Government. The murder of Filipinos due to their pro-American sympathies constitutes a crime resulting from such internal political dissensions. This interpretation aligns with the rule that amnesty proclamations, as acts of grace, should be construed liberally (favorabilia sunt amplianda).
The Court referenced prior decisions (e.g., United States vs. Isidro Guzman, United States vs. Catalino Ortiz, and United States vs. Marcelo de Guzman) which supported a broad interpretation of the proclamation to cover crimes arising from political hatreds or dissensions among Filipinos during the insurrection. Accordingly, the appellant is declared entitled to the amnesty and shall be discharged upon filing the required oath, with costs de oficio.
Note: Justice Willard dissented without an opinion.
