G.R. No. 147375 - Commissioner of Internal Revenue vs. Bank of the Philippine Islands

The case involves accused-appellant Jose N. Patriarca, Jr., also known by various aliases (“Ka Django,” “Carlos Narra,” “Ka Jessie”), who was charged with multiple murders.
The primary incident cited occurred on or about June 30, 1987 in the Municipality of Donsol, Sorsogon, where Alfredo Arevalo – a former CHDF member – was abducted from his residence and shot, resulting in his death.
Other alleged killings include those of Rudy de Borja and Elmer Cadag, with separate criminal cases (Criminal Cases Nos. 2665 and 2672) being filed against Patriarca.

On the evening of June 30, 1987, Patriarca, accompanied by ten armed companions, sought temporary shelter and permission to rest at Nonito Malto’s house in Donsol.
With the assistance of a hogtied person who accompanied the group, Patriarca ordered the lights to be turned off.
At around 2:00 a.m. on July 1, 1987, a gunshot was heard by the witness Malto. He observed Patriarca holding a firearm and directing his companions as they removed the body of the victim.
Subsequent investigations led to the recovery of skeletal remains of Alfredo Arevalo, later identified by the victim’s mother, Elisa Arevalo, through personal effects found with the remains.

Nonito Malto testified to witnessing the events, including the ordering of darkness and the subsequent gunshots which resulted in the death of Alfredo Arevalo.
Elisa Arevalo corroborated the sequence of events by identifying the skeletal remains and recounting her prior interactions with Patriarca, who had previously warned her regarding her son’s associations.

Accused-appellant Jose Patriarca, Jr. and his co-accused admitted to affiliation with the New People’s Army (NPA) but denied involvement in the abduction and killing of the victims.

A joint trial was held for the three criminal cases owing to the substantial similarity in the facts and circumstances.
On January 20, 1998, the Regional Trial Court at Sorsogon, Branch 52, convicted Patriarca of murder in Criminal Case No. 2773 (for Alfredo Arevalo’s death) and imposed reclusion perpetua plus a P50,000 civil indemnity penalty.
In Criminal Cases Nos. 2665 and 2672, the prosecution failed to prove the accused’s guilt beyond reasonable doubt, leading to his acquittal in those instances.

Patriarca filed an application for amnesty under Proclamation No. 724 (amending Proclamation No. 347), which provided for forgiveness of crimes committed in furtherance of political beliefs, including acts associated with rebellion.
The application was favorably recommended by the Local Amnesty Board and subsequently approved by the National Amnesty Commission (NAC) as evidenced in Resolution No. D-99-8683 (initially dated October 22, 1999, and later corrected).
The NAC resolution granted amnesty for crimes committed on or before June 1, 1995, in pursuit of political beliefs, effectively covering the charges against Patriarca.

A notice of the amnesty grant was transmitted by NAC Chairman Alfredo F. Tadiar to the Provincial Prosecutor of Sorsogon, providing the opportunity for appropriate prosecutorial action.
The NAC confirmed that no motion for reconsideration was filed against the resolution, thus finalizing the grant of amnesty.

The Supreme Court, taking judicial notice of the granted amnesty, reversed and set aside the Regional Trial Court’s conviction in Criminal Case No. 2773.
Patriarca was ultimately acquitted of the murder of Alfredo Arevalo, and the other pending cases were similarly dismissed or rendered moot by the amnesty.

Whether the trial court erred in convicting accused-appellant Jose N. Patriarca, Jr. for the crime of murder as committed in furtherance of rebellion, notwithstanding the subsequent grant of amnesty.

The accused argued that his acts, committed in pursuit of his political beliefs as a member of the NPA, fell within the ambit of those eligible for amnesty under Proclamation No. 724.
Whether the grant of amnesty, being a public and binding act, should retrospectively extinguish his criminal liability for the crimes charged.

The proper legal characterization and consequences of amnesty versus pardon, particularly in terms of its retroactive and comprehensive effects on criminal liability.

Distinguishing amnesty—which voids the offense itself—from a pardon that merely mitigates the punishment without expunging the criminal act.