G.R. No. L-885, November 11, 1902
THE UNITED STATES, complainant-appellee, vs. MARCELO DE GUZMAN, defendant-appellant.

FACTS:
Marcelo de Guzman, a captain in the insurgent army during the Philippine insurrection against Spanish rule, was charged with the murder of Pelagio Bonifacio. The evidence established that during the time the insurgents occupied the pueblo of Binmaley, the deceased was brought before De Guzman, accused of being a spy for the Spaniards. After interrogation, during which Bonifacio reportedly admitted to being a spy, De Guzman assaulted him and ordered soldiers under his command to take Bonifacio to a nearby cemetery and execute him, which they did. De Guzman was convicted of murder by the Court of First Instance of Pangasinan and sentenced to life imprisonment. On appeal, he applied for discharge under the amnesty proclamation issued by the President of the United States on July 4, 1902, claiming the act was a political crime committed as part of the insurrection, under military orders, and without personal motive.

ISSUE:
Whether the defendant, Marcelo de Guzman, is entitled to the benefits of the amnesty proclamation and should be discharged from custody.

RULING:
Yes. The Supreme Court granted the application for amnesty and ordered the discharge of Marcelo de Guzman upon his taking the prescribed oath of allegiance. The Court found that the offense was committed by De Guzman in his capacity as an officer of the insurgent army and that it grew out of internal political feuds and dissensions among Filipinos or between Filipinos and Spaniards during the insurrection. Following its previous decisions in similar cases, the Court held that De Guzman brought himself within the scope of the amnesty proclamation. The defendant was to be released from custody upon presenting proof that he had taken and subscribed to the required oath before a competent authority.