G.R. No. L-2012; June 27, 1949
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SOFRONIO GAJO, JULIO NONO, CONRADO GALAPIN, SALVADOR DIAMA, ROMEO AMBID and EMETERIO ZARATE, defendants-appellants.

FACTS

The six appellants, members of a guerrilla unit under Colonel Peralta in Panay, were convicted of triple murder for killing Esperanza Garganera de Nograles and her two sons, Romeo and Augusto Nograles, on September 18, 1944, in Guimaras. The prosecution evidence showed that Corporal Salvador Diama led the group to arrest the victims under orders from Captain Ga, and then ordered their killing on the beach, alleging they were Japanese spies. The defense claimed the killings were a legitimate guerrilla act against spies, done under superior orders. After conviction by the trial court, the appellants sought amnesty under Proclamation No. 8 issued by President Roxas, but the Guerrilla Amnesty Commission initially denied their petition. The case was elevated to the Supreme Court due to the penalty imposed.

ISSUE

Whether the appellants are entitled to amnesty under Proclamation No. 8, which grants amnesty for acts committed in furtherance of the resistance movement during the Japanese occupation.

RULING

Yes. The Supreme Court granted the amnesty, reversing the convictions. The Court found that the killings were politically motivated and committed in the context of the guerrilla resistance against the Japanese. Although there were allegations of personal motives, the evidence created reasonable doubt as to whether the acts were purely criminal or were connected to the resistance movement. Applying the principle that any reasonable doubt should be resolved in favor of the accused under the amnesty proclamation, and considering the Solicitor General’s recommendation, the Court held the appellants entitled to amnesty. The information was dismissed, and the appellants were ordered released.

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