People v. Repollo
REITERATIONFacts
The Antecedents: The defendants, Candido Repollo, Manuel Repollo, Julian Repollo, and Bruno Dolor, were charged with the murder of Proceso Vallesteros on the night of May 16, 1902, and were sentenced to death. Procedural History: After the case was transferred to the Supreme Court, the defendants presented a motion for a new trial, alleging entitlement to the benefits of the amnesty proclamation issued by the President of the United States on July 4, 1902. They supported this motion with affidavits. The Petition: The affidavits detailed that the killing was ordered by Captain Agustin Alejo of the insurrectos, who accused the deceased of being a spy for the Americans. The defendants claimed they were compelled to obey Alejo's orders. The killing occurred after the deceased refused to be taken outside his house. The body was then dragged into the street, and Captain Alejo threatened the defendants if the incident became known. The trial court found that the defendants commanded the deceased to come down and then stabbed him, dragging his body into the street. No personal ill-feeling or motive other than the deceased being a spy was apparent, suggesting a political character to the killing.
Issue(s)
Whether the defendants are entitled to a new trial based on the amnesty proclamation. Whether the evidence presented in the affidavits warrants a new trial.
Ruling
The Supreme Court set aside the judgment, granted a new trial to the defendants, and remanded the case to the Court of First Instance for a new trial.
Ratio Decidendi
On whether the defendants are entitled to a new trial based on the amnesty proclamation: The Court held that while the motion for a new trial was not based on strictly newly discovered evidence, it was based on testimony that became of vital importance to the defendants due to the amnesty proclamation. The Court found the motion to be meritorious in light of the amnesty. On whether the evidence presented in the affidavits warrants a new trial: The Court found the case to be very similar to a previous case, United States vs. Manuel Repollo, Candido Repollo, Bruno Dolor, and Florencio Nicolas. In that case, the defendants were granted a new trial under section 42 of General Orders, No. 58, for reasons stated in the opinion of that case. For those same reasons, the judgment in the present case was set aside, and a new trial was granted.
Main Doctrine
A motion for a new trial based on an amnesty proclamation, even if not strictly newly discovered evidence, may be granted if the amnesty has become of vital importance to the defendants due to its issuance.