G.R. No. 888 : August 16, 1902
Case Title: THE UNITED STATES, complainant-appellee, vs. MANUEL GARCIA, defendant-appellant.

FACTS:
The defendant-appellant, Manuel Garcia, formerly the municipal captain (president) of Manaoag, Pangasinan, was prosecuted for murder in the Court of First Instance. On May 11, 1898, the town was attacked by insurgents. Garcia, commanding the local police and volunteers, repelled the attack, pursued the attackers, and captured two of them. These two prisoners were immediately tried by a summary court-martial presided over by Garcia and were subsequently executed in the town square. Garcia claimed he acted pursuant to instructions from the Spanish civil governor of Pangasinan and was thus exercising his official duties as a Spanish official. On appeal, his counsel moved for the application of the amnesty proclamation issued by the Civil Governor on July 4, 1901.

ISSUE:
Whether Manuel Garcia, having committed the acts charged while acting as a Spanish official, is entitled to the benefits of the amnesty proclamation.

RULING:
No. The Supreme Court denied the motion for amnesty. The amnesty proclamation was intended to cover crimes committed on account of or on the occasion of the revolution against Spanish or American authority. Garcia, at the time of the acts, was a public official exercising authority in the name and representation of the Spanish Government. He was not a rebel or revolutionist but an agent of the colonial power. The Court held that the spirit and letter of the amnesty do not extend to Spanish officials, even if they were Filipino natives, who committed crimes by abusing their public office. The generous purpose of the executive cannot be extended to persons not included within its express terms. The Court emphasized that if Garcia were to seek pardon, it must be solicited as a special favor from the Chief Executive, as the general amnesty is inapplicable to him. The motion was overruled with costs against the appellant.