G.R. No. L-1303, December 12, 1903
THE UNITED STATES, complainant-appellant, vs. JOHN B. COLLEY, defendant-appellee.

FACTS:
The defendant, John B. Colley, a private in the U.S. Army, was charged with the murder of a fellow soldier, Frank Ignasiack, on or about March 29, 1902, in Tarangnan, Samar, during a time of insurrection. He was tried by a duly constituted general court-martial, which found him guilty of murder and sentenced him to death by hanging on June 6, 1902. The record was forwarded for review. However, on July 4, 1902, the President of the United States issued a proclamation declaring the insurrection in the Philippines at an end. Consequently, the military reviewing authority concluded it could no longer proceed under Article of War 58 (which applied in time of war, insurrection, or rebellion) and declined to confirm or execute the sentence. The accused was dishonorably discharged from the army and subsequently turned over to the civil authorities. On January 8, 1903, the Provincial Fiscal of Samar filed an information in the Court of First Instance charging Colley with the same murder. Colley filed a plea of former jeopardy, attaching the court-martial record. The trial judge, after a hearing, sustained the plea and ordered Colley’s discharge. The prosecution appealed.

ISSUE:
Whether the subsequent criminal prosecution of John B. Colley in the civil court for murder constitutes double jeopardy, given his prior trial and conviction by a general court-martial for the same offense.

RULING:
Yes. The Supreme Court affirmed the order of the Court of First Instance discharging the defendant. The Court held that the plea of former jeopardy was valid. The general court-martial was a court of competent jurisdiction at the time of the trial, as the crime was committed and the trial was conducted during a period of insurrection, which gave the military tribunal jurisdiction under Article of War 58. The proceedings and judgment of the court-martial were valid and conclusive. The subsequent proclamation ending the insurrection did not invalidate the completed trial or nullify the jeopardy that had already attached. Furthermore, citing U.S. precedents (particularly Coleman v. Tennessee), the Court held that during the insurrection, the military tribunal had exclusive jurisdiction over the offense committed by a soldier. Therefore, trying the accused again in a civil court for the identical act violated the principle that no person shall be twice put in jeopardy for the same offense.