G.R. No. 1448 : August 22, 1903
SIMEON VILLA, petitioner, vs. HENRY T. ALLEN, Chief Philippines Constabulary, respondent.

FACTS:
On August 8, 1903, an application for a writ of habeas corpus was filed on behalf of Simeon Villa, who was detained by the Chief of the Philippines Constabulary under a warrant issued by the Court of First Instance of Isabela, charging him with the murder of Salvador Piera, a Spanish lieutenant. The murder case had previously been tried against several co-accused, including Dimas Guzman, Isidro Guzman, Ventura Guzman, Jose Guzman, and Cayetano Perez. In that trial, some were acquitted, while Jose Guzman and Isidro Guzman were convicted. On their appeal, the Supreme Court granted them the benefits of the amnesty proclamation of July 4, 1902, and they were released. The petitioner, Villa, argued that the facts of his case were identical to those in the appealed case, showing the murder arose from internal political feuds between Filipinos and Spaniards during the revolution, and that he, as a revolutionary officer, was therefore entitled to the same amnesty benefits. The respondent held Villa pursuant to the warrant, confirming he had not yet been tried.

ISSUE:
Whether the writ of habeas corpus should be granted to release Simeon Villa on the ground that the crime with which he is charged has been extinguished by the amnesty proclamation, thereby rendering his detention illegal.

RULING:
The Supreme Court granted the writ and ordered the release of Simeon Villa. The Court held that the amnesty proclamation operated to obliterate the offense of murder in this instance, as it was determined to have grown out of internal political feuds between Filipinos and Spaniardsa category of offenses covered by the proclamation. Since the Supreme Court had already declared in the case of his co-accused that the crime was included within the amnesty, the crime was considered “wiped out, pardoned, and forgotten.” Consequently, the warrant of arrest, issued prior to the amnesty, had lapsed, and there no longer existed any crime for which Villa could be prosecuted. The Court distinguished amnesty (which operates objectively on the crime itself) from pardon (which operates subjectively on the individual), and found that the amnesty removed the legal basis for detention. Therefore, Villa was entitled to be discharged without being remanded for trial, upon taking the oath prescribed in the amnesty proclamation.