Title
People vs Garcia
Case
G.R. No. 888
Decision Date
Aug 16, 1902
A municipal president accused of murder during his official duties is denied amnesty as his status and the amnesty's scope preclude eligibility.
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Case Digest (G.R. No. 888)

Facts:

  • The case involved The United States vs. Manuel Garcia, prosecuted in the Court of First Instance of Pangasinan.
  • Manuel Garcia was the former municipal captain of Manaoag, Pangasinan.
  • On May 11, 1898, the town faced an attack from insurgents.
  • Garcia led local police and volunteers to repel the attack and captured two insurgents.
  • A summary court-martial, presided over by Garcia, resulted in the immediate execution of the captured insurgents.
  • Garcia claimed his actions were based on instructions from the civil governor of Pangasinan, representing the Spanish Government.
  • He was charged with double murder for the killings.
  • Garcia appealed, arguing that the charges fell under an amnesty proclamation issued on July 4, 1902, by the Civil Governor in the name of the President of the United States.

Issue:

  • (Unlock)

Ruling:

  • The court ruled that Manuel Garcia was not entitled to the benefits of the amnesty proclamation.
  • Garcia's attorney's mo...(Unlock)

Ratio:

  • The court interpreted the amnesty proclamation and its applicable conditions.
  • The amnesty was intended for individuals involved in the political movement during the revolution.
  • Garcia, as a public official of the Spanish Government, was not eligible for amnesty.
  • The proclamation did not cover public officials who abu...continue reading

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