G.R. No. L-4316, May 28, 1952.
People of the Philippines, petitioner, vs. Hon. Higinio Macadaeg, Hon. Potenciano Pecson, Hon. Ramon San Jose, as Chairman and Members, respectively, of the Seventh Guerrilla Amnesty Commission, and Antonio Guillermo, alias Silver, as an interested party, respondents.

FACTS

The petitioner, the People of the Philippines, seeks to prohibit the Seventh Guerrilla Amnesty Commission from taking cognizance of a petition for amnesty filed by respondent Antonio Guillermo. Guillermo had been convicted of murder by the Supreme Court on May 19, 1950, in G.R. No. L-2188. In that decision, the Supreme Court expressly ruled that Guillermo was not entitled to amnesty because the murders were committed “not in furtherance of the resistance movement but in the course of a fratricidal strife between two rival guerilla units.” Guillermo filed his amnesty petition with the Commission on July 8, 1950, after his motion for reconsideration and a motion to refer the case to the Commission had been denied by the Supreme Court. The Commission set the case for hearing, prompting this prohibition action. The petitioner argues that (1) the Supreme Court’s ruling on amnesty is final and precludes relitigation, and (2) the Seventh Commission lacks jurisdiction as it was created to handle cases pending appeal in the Supreme Court on October 2, 1946, whereas Guillermo’s case was still in the Court of First Instance at that time.

ISSUE

1. Whether the Supreme Court’s prior ruling that Antonio Guillermo is not entitled to amnesty constitutes a final and conclusive determination that bars him from raising the issue again before the Guerrilla Amnesty Commission.
2. Whether the Seventh Guerrilla Amnesty Commission has jurisdiction to entertain Guillermo’s petition for amnesty.

RULING

1. Yes. The Supreme Court held that its prior ruling on amnesty was not an obiter dictum but a direct and essential determination on an issue expressly raised by Guillermo during his appeal. The Court examined the evidence and conclusively found the killings were part of an internal guerrilla conflict, not in furtherance of the resistance. This finding is final under the principle of res judicata and estops Guillermo from relitigating the issue. The Court distinguished the case from Viray vs. Crisologo, as Guillermo had already raised the amnesty issue during his appeal, whereas in Viray, the defendant only invoked amnesty after conviction.
2. No. The Supreme Court held that the Seventh Guerrilla Amnesty Commission lacked jurisdiction. Administrative Order No. 11, which created the commissions, assigned to the Seventh Commission only “cases from the different provinces and cities now pending appeal in the Supreme Court” as of October 2, 1946. Guillermo’s case was still pending in the Court of First Instance of Ilocos Norte on that date and was thus cognizable by the Second Guerrilla Amnesty Commission. A subsequent Department of Justice order did not modify this jurisdictional allocation.
The petition for prohibition was granted, and the preliminary injunction was made permanent, with costs against respondent Antonio Guillermo.