G.R. No. L-985, November 10, 1902
THE UNITED STATES, complainant-appellant, vs. ANACLETO SANTILLANA, ET AL., defendants-appellees.

FACTS:
On September 7, 1899, Don Juan Carballo y Blanco was killed on his hacienda in Negros Occidental by a band of armed men. Three days later, his severed head was found displayed on a bridge with an inscription labeling him as “pernicious to the revolution.” The killing was carried out pursuant to a written order issued by a revolutionary council of war, which was then operating against the United States in the province. The defendant, Anacleto Santillana, acted as the judge-advocate before this council. The order, which he delivered for execution, charged Carballo with being a spy and guide for the Americans and directed that he be brought for trial, but if he resisted, he should be killed. Carballo was attacked and killed without any attempt to arrest him. The defendant was tried for murder and acquitted by the lower court. The prosecution appealed. During the appeal, the Solicitor-General moved for the defendant’s discharge based on the amnesty proclamation of July 4, 1902. The defendant, while also arguing the merits, claimed the benefit of the amnesty and filed the required oath.

ISSUE:
Whether the defendant is entitled to the benefits of the amnesty proclamation of July 4, 1902, for his participation in the killing of Don Juan Carballo.

RULING:
Yes. The Supreme Court held that the defendant’s case clearly falls within the terms of the amnesty proclamation. The Court found that the defendant was participating in the revolution against the United States and was acting pursuant to the orders of his superior, Luis Ginete. Following its precedent in United States vs. Vicente Villamor, the Court ruled that the killing of Don Juan Carballo was an offense of a political character committed in the context of the revolution. Without deciding the underlying questions of legal responsibility for the actwhich the Court deemed unnecessary to resolve given the applicability of amnestythe Court held that the defendant is included in the amnesty. Since he had filed the required oath, the case was dismissed. The acquittal by the lower court was thus left undisturbed.