G.R. No. L-590 : October 10, 1902
Case Title: The United States vs. Isidro Guzman, et al.

FACTS:
The accused, Isidro Guzman and Jose Guzman, were convicted of murder by the Court of First Instance of Isabela and sentenced to life imprisonment for the killing of Salvador Piera, a lieutenant in the Spanish army. The crime occurred around September or October 1898. The evidence showed that the accused, acting under orders from Major Simeon Villa of the revolutionary army, brutally beat, tortured, and hanged Piera until he died. The motive was rooted in political hatred, as Dimas Guzman (a relative) sought revenge against Piera, who had acted as a judge in a prior military prosecution against him during the Spanish regime. After their conviction, the appellants filed a motion before the Supreme Court seeking the benefits of the general amnesty proclaimed by the President of the United States on July 4, 1902.

ISSUE:
Whether or not the appellants, Isidro Guzman and Jose Guzman, are entitled to the benefits of the amnesty proclamation of July 4, 1902, thereby warranting the dismissal of the criminal case against them.

RULING:
Yes. The Supreme Court granted the motion and held that the appellants are included within the scope of the amnesty proclamation. The Court ruled that although the crime was murdera common crimeit was committed as a result of political hatred and dissensions between Filipinos and Spaniards or Spanish authorities during the insurrection against Spain. The amnesty was a political act of the sovereign power, intended to remit offenses arising from the revolution and internal political feuds. The Court found that the appellants were officers in the revolutionary army and that the killing of Piera was a direct consequence of political enmity. Therefore, in obedience to the sovereign will and for reasons of state and humanity, the amnesty applied. The appellants were to be released upon taking the prescribed oath, and the case was ordered dismissed.