GR L 3879; (April, 1951) (Digest)
G.R. No. L-3879 April 27, 1951
MONTSERRAT D. AQUINO, petitioner, vs. PHILIPPINE ARMY AMNESTY COMMISSION and CAPTAIN TOMAS YQUIN, respondents.
FACTS
Petitioner Montserrat D. Aquino, widow of Potenciano Aquino, filed a petition for a writ of prohibition. The Provincial Fiscal of Cagayan filed an information for murder against respondent Captain Tomas Yquin, an active Philippine Army officer, and others before the Justice of the Peace Court of Sanchez Mira, Cagayan (Criminal Case No. 1610). After the issuance of Amnesty Proclamation No. 8, the Fiscal cited Yquin, who initially declined to avail of amnesty. Yquin later filed a petition with the Philippine Army Amnesty Commission. When asked by the Commission if he pleaded guilty, he answered negatively and requested to withdraw his amnesty petition, which was granted. The Fiscal refiled the information, and the court issued arrest orders. Before arrest, Yquin filed a new application for amnesty, halting proceedings in the Justice of the Peace Court. Petitioner objected to the readmission of Yquin’s petition, arguing that its prior withdrawal barred its reinstatement. The Commission overruled the objection.
ISSUE
Whether the Philippine Army Amnesty Commission can proceed with the investigation of Captain Tomas Yquin’s amnesty application after he had previously withdrawn it.
RULING
The petition is denied. The Court held that Yquin’s prior refusal to plead guilty and withdrawal of his amnesty application does not constitute estoppel. An accused may change their plea, and there is no provision in the Amnesty Proclamation or its implementing orders preventing the filing of an application after withdrawal. Yquin withdrew his initial petition partly under the mistaken impression that a guilty plea was required. His acts do not meet the legal definition of estoppel under Rule 123, section 68(a), as he is not attempting to falsify a prior statement to the petitioner. The Philippine Army Amnesty Commission has authority to investigate Yquin, an active army officer, as established in prior jurisprudence (Viray vs. Amnesty Commission). The distribution of cases among Amnesty Commissions is administrative and does not affect jurisdiction in a manner that parties cannot waive. The amnesty process is intended to be liberal and expeditious.