G.R. No. L-964, November 4, 1902
THE UNITED STATES, complainant-appellee, vs. CATALINO ORTIZ, ET AL., defendants-appellants.

FACTS:
In July 1901, Mariano de Mesa, a prisoner held by a group of revolutionists commanded by Major Ruperto Reus, was killed under the belief that he was a spy for the American Army. The actual killing was carried out by defendants Catalino Ortiz and Miguel Arevalo, upon the order of defendant Germiniano Almagro, who was the captain of the party and who acted upon instructions from Major Reus. To ensure the crime’s consummation, the victim was tied to a telegraph pole and, while defenseless, was inflicted with three fatal wounds. The body was later found with a note stating he was killed as a spy. The defendants were convicted of murder by the Court of First Instance of Mauban, Tayabas, and sentenced to life imprisonment (cadena perpetua). Only Miguel Arevalo and Germiniano Almagro appealed the judgment. While the appeal was pending, a joint motion was filed requesting that the defendants be granted the benefits of the Amnesty Proclamation of July 4, 1902.

ISSUE:
Whether the defendants are entitled to the benefits of the Amnesty Proclamation of July 4, 1902.

RULING:
Yes, in part. The Supreme Court ruled that the crime was political in character, arising from the political dissensions during the revolution, as it was committed by revolutionists against a supposed spy for the American Army upon orders of their military commander, and not due to personal motives.
As to appellants Miguel Arevalo and Germiniano Almagro: Since their conviction was not yet final (their appeal was pending), they were entitled to the benefits of the amnesty. They were to be set at liberty upon taking the prescribed oath before a competent officer.
As to defendant Catalino Ortiz: Since he did not appeal, the judgment against him had become final. Consequently, he fell under an exception in the amnesty decree, and the Court lacked jurisdiction to apply the amnesty to him. His recourse was to file a special petition with the proper executive authorities.
The Court directed the lower court judge to forward proof of compliance regarding the appellants’ oath-taking.