G.R. No. 1280 : August 19, 1903
THE UNITED STATES, complainant-appellee, vs. ISIDORO MADLANGBAYAN, ET AL., defendants-appellants.

FACTS:
The defendants, Isidoro Madlangbayan and Blas Panaligan, were charged with the killing of one Cusi. The prosecution alleged that Panaligan killed Cusi upon the order of Madlangbayan. At trial, Panaligan admitted to the killing but testified that he was a member of the insurgent forces at the time (August 1900) and that he acted upon the order of his military captain, Juan Tosing, to seize Cusi as a spy and kill him if he resisted. Captain Tosing corroborated this testimony. The only evidence implicating Madlangbayan was the testimony of Benito Cusi, who claimed that Madlangbayan confessed to ordering the killing. The trial court convicted both defendants but granted them the benefits of the Amnesty Proclamation of July 4, 1902, while also ordering them to pay indemnity to the heirs of the deceased.

ISSUE:
1. Whether the evidence was sufficient to convict Isidoro Madlangbayan as a principal by inducement.

3. Whether the trial court could properly award civil indemnity after applying the amnesty and dismissing the criminal case.

RULING:
1. As to Isidoro Madlangbayan: The Supreme Court ACQUITTED him. The evidence against him was deemed insufficient. The testimony of Benito Cusi regarding an alleged confession was outweighed by the denial of both defendants and the positive testimony of other witnesses, including Captain Tosing, that the killing was done under military orders from a different superior. The Court found no credible evidence proving Madlangbayan ordered the crime.

3. As to the Civil Indemnity: The Supreme Court held that while the amnesty extinguishes criminal liability, it does not extinguish civil liability arising from the crime. The trial court’s dismissal of the criminal case upon application of the amnesty was proper, but the accompanying order for indemnity was procedurally incorrect in the criminal proceeding. The dismissal is without prejudice to the right of the widow and heirs to enforce the civil responsibility of Blas Panaligan in a separate civil action.

DISPOSITIVE PORTION:
The judgment of the lower court is REVERSED. Isidoro Madlangbayan is acquitted. Blas Panaligan is declared entitled to the benefits of the amnesty; upon filing the required oath, the case against him shall be dismissed. The dismissal is without prejudice to any civil action for damages.