G.R. No. L-18184. January 31, 1963.
GAUDENCIO VERA, RESTITUTO FIGUERAS, LORENZO AMBAS, JUSTO FLORIDO, PAULINO BAYRAN AND JAYME GARCIA, petitioners, vs. PEOPLE OF THE PHILIPPINES and COURT OF APPEALS, respondents.

FACTS

Petitioners were charged with the complex crime of kidnapping with murder before the Court of First Instance of Quezon. Invoking the benefits of Amnesty Proclamation No. 8 (1946), the case was referred to the Eighth Guerrilla Amnesty Commission. During the Commission hearing, none of the petitioners admitted to committing the crime. Gaudencio Vera, the sole petitioner to testify, categorically denied any involvement in the killing. Consequently, the Commission, in its 1956 decision, declined jurisdiction. It ruled that the amnesty could only be invoked by an accused who admits the commission of the crime and pleads that it was done in furtherance of the resistance movement or against persons aiding the enemy. The Commission ordered the case remanded to the court of origin for trial.
The Commission, in denying a motion for reconsideration, made factual findings that the killing stemmed from rivalry between guerrilla units (the Vera Guerrillas and the Hunters ROTC Guerrilla to which the victim belonged) and was not in furtherance of the resistance movement. The Court of Appeals later affirmed the Commission’s order. Petitioners appealed, arguing factual issues regarding the victim’s alleged collaboration with the enemy, which they claimed would bring the act within the amnesty.

ISSUE

Whether petitioners are entitled to the benefits of Amnesty Proclamation No. 8.

RULING

No. The Supreme Court affirmed the decision of the Court of Appeals, holding that petitioners are not entitled to amnesty. The legal logic is twofold. First, amnesty presupposes the commission of a crime; it is an act of sovereign grace extended to those who admit guilt for acts falling within its scope. Following precedents like Llanita and Guillermo, the Court ruled that an accused who denies the commission of the offense charged cannot invoke amnesty. Here, petitioners did not admit the acts; they denied them. Therefore, the Amnesty Commission correctly refused jurisdiction, as its authority was contingent upon such an admission.
Second, even assuming jurisdiction, the factual findings of the Commission, which the Court found no reason to disturb, established that the killing was motivated by inter-guerrilla rivalry, not by a desire to further the resistance movement or punish a person aiding the enemy. Amnesty Proclamation No. 8 applies only to acts committed “in furtherance of the resistance to the enemy or against persons aiding in the war effort of the enemy.” The Commission’s finding that the act weakened the resistance movement by targeting a fellow guerrilla lieutenant placed it outside the proclamation’s coverage. The Court also found no error in the Court of Appeals’ refusal to rule on the factual issues raised by petitioners, as doing so would be premature and prejudicial since the Commission lacked jurisdiction from the outset.