Case Digest (G.R. No. 151370) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Gaudencio Vera, Restituto Figueras, Lorenzo Ambas, Justo Florido, Paulino Bayban and Jaime Garcia v. People of the Philippines and Court of Appeals (G.R. No. L-18184, January 31, 1963), petitioners, all members of the Vera guerrilla group in Quezon province during the Japanese occupation, were charged before the Court of First Instance of Quezon with the complex crime of kidnapping with murder of Amadeo Lozanes, alias Azarcon, a lieutenant of the Hunters ROTC guerrilla unit. In 1955 they filed a motion invoking the benefits of Amnesty Proclamation No. 8 (September 7, 1946) and their case was referred to the Eighth Guerrilla Amnesty Commission. At the hearing none of the accused admitted participation; Vera himself emphatically denied the killing. On January 12, 1956, the Commission ruled it lacked jurisdiction because the proclamation required an admission that the act was committed in furtherance of the resistance against the Japanese or against enemy collaborators, and orde Case Digest (G.R. No. 151370) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Nature of the case and parties
- Petitioners Gaudencio Vera, Restituto Figueras, Lorenzo Ambas, Justo Florido, Paulino Bayran, Jaime Garcia and 92 others (as John Does) were charged before the Court of First Instance of Quezon with the complex crime of kidnapping with murder of Amadeo Lozanes (alias Azarcon).
- Petitioners invoked the benefits of Amnesty Proclamation No. 8 (September 7, 1946) and moved that the case be referred to the Eighth Guerrilla Amnesty Commission (“the Commission”) for determination.
- Proceedings before the Eighth Guerrilla Amnesty Commission and the Court of Appeals
- At the Commission hearing, no petitioner admitted having committed the crime in furtherance of the resistance movement; instead, the sole witness-defendant who testified (Gaudencio Vera) denied killing Lozanes.
- In its January 12, 1956 decision, the Commission held it lacked jurisdiction because petitioners failed to admit the commission of the crime as required by the Amnesty Proclamation and Administrative Order No. 144, and remanded the case to the trial court.
- A motion for reconsideration was denied (January 11, 1957), after which petitioners appealed to the Court of Appeals.
- The Court of Appeals certified to the Supreme Court the legal issue of whether invocation of amnesty requires prior admission of the crime, then, upon return of the record, affirmed the Commission’s order (November 16, 1960), holding that:
- Administrative Order No. 144 explicitly mandates a verbal or written admission of commission in furtherance of the resistance or against enemy collaborators;
- Petitioners instead denied the charge, depriving the Commission of jurisdiction; and
- It would be premature and useless to resolve underlying factual questions on motive since jurisdiction was lacking.
Issues:
- Whether persons invoking the benefit of Amnesty Proclamation No. 8 must first admit having committed the crime charged.
- Whether the Court of Appeals erred in declining to resolve factual issues raised by petitioners regarding the motive and circumstances of Amadeo Lozanes’s kidnapping and killing.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)