G.R. No. L-5930, April 5, 1911
THE UNITED STATES vs. LEOCADIO PAJARILLO, ET AL.

FACTS

On a night in May 1900, in Sapian, Capiz, Ciriaco Occeño, a deputy police officer under the local revolutionary government, was shot and killed in his home. The accusedbrothers Leocadio, Tranquilino, and Juan Pajarillo, along with Francisco Orleanswere charged with asesinato (murder). The prosecution presented witnesses, including the victim’s sister Maxima Occeño and brother-in-law Esteban Obidos, who testified that the accused, armed with guns, went to Occeño’s house at dawn, forced Obidos to call Occeño out, and upon Occeño appearing at the door, Leocadio ordered the others to fire, killing him instantly. The defense claimed the act was covered by the amnesty proclamation of July 4, 1902, as it occurred during the Philippine insurrection and was politically motivated, alleging Occeño was suspected of disloyalty to the revolutionary cause.

ISSUE

Whether the appellants are entitled to amnesty under the proclamation of July 4, 1902, which pardoned political offenses committed during the insurrection.

RULING

No. The Supreme Court affirmed the conviction and sentence of cadena perpetua (life imprisonment). The Court held that the crime was not political in character and thus not covered by the amnesty. While the killing occurred during the insurrection, the evidence showed it was motivated by personal reasonsspecifically, Leocadio Pajarillo’s illicit relationship with Occeño’s wiferather than political necessity or expediency. The act was committed with treachery (alevosía) and premeditation, as the accused ambushed Occeño in his home without provocation or opportunity to defend himself. The Court found that the offense was a common crime, not incidental to or in furtherance of political aims, and therefore the amnesty did not apply. The judgment of the Court of First Instance was affirmed.