Case Digest (G.R. No. L-3879)
Facts:
The case involves Montserrat D. Aquino as the petitioner and the Philippine Army Amnesty Commission along with Captain Tomas Yquin as the respondents. Montserrat D. Aquino is the widow of Potenciano Aquino, who was murdered. The events leading to this case began on August 31, 1946, when the Provincial Fiscal of Cagayan filed an information against Captain Tomas Yquin and others for the murder of Potenciano Aquino in the Justice of the Peace Court of Sanchez Mira, Cagayan, under Criminal Case No. 1610. On September 7, 1946, the President of the Philippines issued Amnesty Proclamation No. 8, which led to the creation of the Guerrilla Amnesty Commissions and the Philippine Army Amnesty Commission through Administrative Orders No. 11 and No. 17. The Provincial Fiscal, who had initiated the case against Yquin, summoned him to inquire if he wished to avail himself of the amnesty. Initially, Yquin declined the offer. However, he later filed a petition with the Philippine Army Amnest...
Case Digest (G.R. No. L-3879)
Facts:
Background of the Case:
Montserrat D. Aquino, the petitioner, is the widow of Potenciano Aquino, who was murdered. She resides in Pamplona, Cagayan. The respondent, Captain Tomas Yquin, is an officer of the Philippine Army in active service.
Initiation of Criminal Proceedings:
On August 31, 1946, the Provincial Fiscal of Cagayan filed an information with the Justice of the Peace Court of Sanchez Mira, Cagayan, accusing Captain Tomas Yquin and others of the murder of Potenciano Aquino and others (Criminal Case No. 1610).
Amnesty Proclamation and Initial Application:
On September 7, 1946, President Manuel Roxas issued Amnesty Proclamation No. 8, which allowed certain individuals to seek amnesty for crimes committed during wartime. Pursuant to Administrative Orders No. 11 and 17, the Philippine Army Amnesty Commission was created to investigate claims for amnesty. The Provincial Fiscal cited Captain Yquin to appear before him and inquired whether he wanted to avail himself of the amnesty. Yquin initially declined.
Withdrawal and Reapplication for Amnesty:
Yquin later filed a petition with the Philippine Army Amnesty Commission to investigate his claim for amnesty. However, when he appeared before the Commission, he withdrew his petition after learning that a plea of guilty was not necessary. Despite his withdrawal, Yquin reapplied for amnesty, and the Commission proceeded with the investigation.
Petitioner’s Objection:
Montserrat D. Aquino, through her counsel, objected to the readmission of Yquin’s petition on the grounds of estoppel, arguing that having withdrawn it with the Commission’s approval, the petition could not be readmitted. The overruled her objection, and she sought a writ of prohibition from the Supreme Court to halt the investigation.
Issue:
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Ruling:
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Ratio:
- Readmission of Amnesty Application: There is no provision in the Amnesty Proclamation or its implementing administrative orders that prevents the readmission of an application for amnesty after it has been withdrawn. The withdrawal of an application does not create a permanent bar to its re-filing.
- Estoppel Not Applicable: Estoppel does not apply because Yquin did not make any false representation or mislead the petitioner. His actions were based on a misunderstanding of the requirement to plead guilty, which was later clarified by the Supreme Court.
- Authority of the Commission: The Philippine Army Amnesty Commission has the authority to investigate cases involving officers in active service. The investigation process is to be conducted in a liberal and expeditious manner, in line with the spirit of the Amnesty Proclamation.
- Expeditious Proceedings: The Court emphasized that the amnesty process should be carried out swiftly and without unnecessary delay, as intended by the Proclamation and its implementing orders.