G.R. No. 1332 : July 31, 1903
THE UNITED STATES, complainant-appellee, vs. GERONIMO LUZON, defendant-appellant.

FACTS:
The defendant-appellant, Geronimo Luzon, was convicted of the crime of illegal detention. The evidence established that in November 1900, in the Province of Bulacan, Luzon, as the leader of an armed band of six persons, went to the house of Gregorio Mistica. The band compelled Mistica and his wife, Caledonia Santos, to leave their house, robbed it, and then took the couple to a neighboring barrio. The husband was separated from the wife, who was placed under Luzon’s guard. The rest of the band took the husband into the woods and later returned stating he had been killed. The wife was detained for nine days until she escaped when her guards were frightened by approaching American soldiers. At the trial, it was shown that the members of the band were soldiers of the insurrectionary forces. Luzon filed a motion to be included in the amnesty granted by the Presidential Proclamation of July 4, 1902.

ISSUE:
Whether or not the defendant-appellant Geronimo Luzon is entitled to the benefits of the amnesty proclamation of July 4, 1902.

RULING:
No, the defendant-appellant is not entitled to amnesty. The Supreme Court denied the motion.
To be entitled to the amnesty, two conditions must concur: (1) the person must have participated in the insurrections against Spain or the United States, and (2) the crime charged must be political in nature. Common crimes like murder, robbery, and illegal detention are not included unless committed under circumstances that give them a political character.
In this case, while it was proven that Luzon and his band were insurrectionary soldiers, there was no evidence presented that the crime of illegal detention and robbery was politically motivated. The Court found nothing in the record to indicate that the victims were perceived as spies or enemies of the insurrection. The offense occurred at a time (November 1900) and in a place (Bulacan) where organized insurgent forces had largely dissipated, and the band’s actions appeared to be those of outlaws. The Court refused to apply a presumption that any crime committed by former soldiers was political, as such a construction would lead to the release of numerous individuals who committed atrocities for private ends, contrary to the proclamation’s purpose. Since the political character of the crime was not established, Luzon was not covered by the amnesty.
The dissenting opinion argued for a more liberal construction of the amnesty proclamation, contending that the crime, committed by a band of soldiers during the insurrection, should be presumed to be political and incidental to the disturbances of that period.