G.R. No. L-11487; July 22, 1916
THE UNITED STATES, plaintiff-appellee, vs. MANUEL CATALAN, defendant-appellant.

FACTS:
The accused, Manuel Catalan, was charged with the crime of murder. The information alleged that on or about May 1900, within the municipality of Cabatuan, Province of Iloilo, he voluntarily, illegally, criminally, and with known premeditation and treachery killed Valentin Jordan by shooting him with a gun. After trial, the lower court found Catalan guilty of murder and sentenced him to twenty years of cadena temporal. Catalan appealed the judgment.

ISSUE:
1. Whether the guilt of the appellant was proved beyond a reasonable doubt.
2. Whether, assuming the appellant killed the deceased, the act was exempt from criminal liability under the Amnesty Proclamation of July 4, 1902.

RULING:
The Supreme Court REVERSED the judgment of conviction and ACQUITTED the accused, Manuel Catalan.

The Court agreed with the recommendation of the Attorney-General for acquittal on two grounds. First, the evidence for the prosecution was not satisfactory to establish guilt beyond a reasonable doubt. Second, and more decisively, the defense clearly established that the deceased, Valentin Jordan, was shot pursuant to the decision of a court-martial instituted by officers of the revolutionary army in May 1900. The court-martial tried and found Jordan guilty of being a spy for the American Army and a bandolero (highway robber). Testimony and corroborative evidence showed that the execution was a result of this judgment.

Therefore, the killing was an act carried out under the authority of the revolutionary forces and was covered by the Amnesty Proclamation of July 4, 1902, which granted amnesty for acts committed in furtherance of the Philippine insurrection. The accused was ordered released immediately from imprisonment.