People v. Guillermo
REITERATIONFacts
The Antecedents: Respondent Antonio Guillermo was convicted of murder by the Supreme Court on May 19, 1950, in G.R. No. L-2188. The Supreme Court's judgment explicitly stated that Guillermo was not entitled to amnesty because the murders were committed "not in furtherance of the resistance movement but in the course of a fratricidal strife between two rival guerilla units." Procedural History: Guillermo filed a motion for reconsideration, which was denied. He also filed a motion with the Supreme Court to suspend proceedings and refer his case to the Seventh Guerrilla Amnesty Commission, which was also denied. Subsequently, Guillermo filed a petition for amnesty with the Seventh Guerrilla Amnesty Commission. The Commission required the forwarding of the case records and set the case for hearing over the opposition of the Solicitor General. The Petition: The People of the Philippines filed an action for prohibition against the Seventh Guerrilla Amnesty Commission and Antonio Guillermo to restrain the Commission from taking cognizance of Guillermo's petition for amnesty.
Issue(s)
Whether the Supreme Court's prior ruling that respondent Antonio Guillermo is not entitled to amnesty constitutes an obiter dictum. Whether respondent Antonio Guillermo is estopped from raising the issue of amnesty before the Seventh Guerrilla Amnesty Commission after the Supreme Court had already ruled on the matter. Whether the Seventh Guerrilla Amnesty Commission has jurisdiction to take cognizance of respondent Antonio Guillermo's petition for amnesty.
Ruling
The petition for prohibition is granted. The Seventh Guerrilla Amnesty Commission is restrained from taking cognizance of the petition for amnesty filed by Antonio Guillermo.
Ratio Decidendi
On the issue of whether the Supreme Court's prior ruling is an obiter dictum: The Court held that the ruling that respondent Guillermo is not entitled to the benefits of amnesty is not an obiter dictum but a direct ruling on an issue expressly raised by the party appellant and was essential to the determination of the case. An obiter dictum is an opinion uttered by the way, not upon the point or question pending, or an opinion of the court upon any point or principle which it is not required to decide. The ruling in Guillermo's case was made after arguments on both sides had been heard and was a deliberate determination of a point in issue. Therefore, it was not an obiter dictum but a binding pronouncement. On the issue of estoppel and res judicata: The Court ruled that respondent Guillermo is estopped from contesting the judgment and the authority of the court that rendered the adverse ruling on his claim for amnesty. The general rule common to all civilized systems of jurisprudence is that the solemn and deliberate sentence of the law, pronounced by its appointed organs, upon a disputed fact or state of facts, should be regarded as a final and conclusive determination of the question litigated. Having voluntarily raised the issue of amnesty before the Supreme Court during the consideration of his case, he is now precluded from raising it again before an administrative body. The Court inferred from the circumstances that amnesty was not considered a defense until after conviction, suggesting a last-ditch attempt to delay execution of the judgment. On the issue of the Commission's jurisdiction: The Court found that the Seventh Guerrilla Amnesty Commission does not have jurisdiction over respondent Guillermo's application. Administrative Order No. 11, which created the commission, assigned to the Seventh cases "now pending appeal in the Supreme Court" as of October 2, 1946. At that time, Guillermo's case was still pending in the Court of First Instance of Ilocos Norte. The subsequent Administrative Order No. 217, cited by the respondents, was issued for a different purpose and cannot be interpreted to modify the President's administrative order apportioning cases among the amnesty commissions. Therefore, the respondent Commission lacks the authority to hear the case.
Main Doctrine
A prior ruling by the Supreme Court on the inapplicability of amnesty to a convicted individual, when such issue was expressly raised and decided, is final and conclusive and bars the individual from raising the same issue before an amnesty commission, under the principle of res judicata and estoppel. Furthermore, an amnesty commission may not have jurisdiction over cases already decided with finality by the Supreme Court.