G.R. Nos. L-77317-50; July 29, 1987
Madid Macaga-an, et al. vs. People of the Philippines and the Sandiganbayan

FACTS

The petitioners, consisting of municipal and provincial treasurers and auditors from Lanao del Norte and Lanao del Sur, were convicted by the Sandiganbayan in 1981 for estafa through falsification of public documents, involving over P2.7 million in government funds. In March 1986, they moved for the closure of their cases and release of their bonds, claiming they had been granted amnesty by former President Ferdinand Marcos on January 28, 1986. The Sandiganbayan required them to submit original or authenticated copies of their amnesty papers, which they could not produce, leading to the denial of their motion.
In their motion for reconsideration, petitioners sought to present secondary evidence to prove the alleged amnesty. They asserted that their applications, endorsed by an Amnesty Commission, were submitted to the Office of the President and that former President Marcos had handwritten “Approved” on a related letter dated January 27, 1986. They claimed the original documents were lost or destroyed in Malacañang during the February 1986 revolution. The Sandiganbayan denied the motion, holding that even if proven, amnesty was not available to them under the applicable law.

ISSUE

Whether the Sandiganbayan committed reversible error in: (1) holding that Presidential Decree No. 1082, as amended, did not apply to petitioners, and (2) not allowing them to present secondary evidence of the alleged amnesty grant.

RULING

The Supreme Court denied the petition and affirmed the Sandiganbayan’s resolution. The legal logic is clear: Amnesty under P.D. No. 1082, as amended by P.D. No. 1182 and P.D. No. 1429, is explicitly limited to crimes committed “in furtherance of subversion or crimes against public order.” The petitioners were convicted of ordinary crimes—estafa through falsification—involving the systematic diversion of public funds for private profit, acts devoid of any political motivation or connection to rebellion or public order offenses. The law expressly disqualifies those who “diverted public funds from the lawful purpose for which they had been appropriated.”
Consequently, even if petitioners could authenticate the alleged amnesty through secondary evidence, they would not be entitled to its benefits, as the grant would have been void for contravening the restrictive terms of the very decrees issued by former President Marcos. The Court emphasized that the former President, in exercising legislative power through decrees, was bound by their conditions; any executive act violating those conditions could not be given legal effect. The proper recourse for any unfulfilled expectations lies with the Executive Department, not the judiciary.