Amnesty presupposes the commission of a crime; therefore, an accused who denies committing the offense charged cannot simultaneously invoke the benefits of an amnesty proclamation, as amnesty is in the nature of a plea of confession and avoidance.

The case arose in the aftermath of World War II in the Philippines, during which various guerrilla units operated. The Amnesty Proclamation No. 8, series of 1946, was issued to provide a means for individuals who committed acts penalized under the Revised Penal Code in furtherance of the resistance movement against the Japanese or against persons aiding the enemy to be absolved of criminal liability. The petitioners were members of Vera's Guerrilla Party, and the victim, Amadeo Lozañes, was a lieutenant of the Hunter's ROTC Guerrilla organization, with a history of rivalry between the two groups.

• Petitioners Gaudencio Vera, Restituto Figueras, Lorenzo Ambas, Justo Florido, Paulino Bayban, and 92 others were charged in the Court of First Instance of Quezon with the complex crime of kidnapping with murder of Amadeo Lozañes, alias Azarcon.
• Upon petitioners' motion, the case was referred to the Eighth Guerilla Amnesty Commission for them to invoke the benefits of Amnesty Proclamation No. 8, series of 1946.
• During the hearing before the Commission, none of the petitioners admitted committing the crime; petitioner Gaudencio Vera, the only defendant who testified, categorically denied killing Lozañes.
• The Commission found that the motive for the kidnapping and killing of Lt. Amadeo Lozañes was the keen rivalry between Vera's Guerrilla Party and the Hunter's ROTC Guerrilla organization, to which Lozañes belonged.
• The Commission also noted that Lozañes was a lieutenant of the Hunter's ROTC Guerrilla organization, engaged in the resistance movement, and thus his killing could not be considered as furthering the resistance movement.
• The Commission determined it could not take cognizance of the case because the benefits of the Amnesty Proclamation could only be invoked by defendants who admit committing the crime and plead it was in pursuance of the resistance movement.
• The Commission also noted no evidence showed defendant Jaime Garcia participated in the crime or admitted/disclaimed any role.

• Petitioners contended that to be entitled to the benefits of Amnesty Proclamation No. 8, it is not necessary for them to admit the commission of the crime charged as a condition precedent or sine qua non.
• Petitioners argued it is sufficient that the evidence, either of the complainant or the accused, shows that the offense committed comes within the terms of the Amnesty Proclamation.
• Petitioners claimed they had impliedly admitted their participation in the killing of Amadeo Lozañes in their motion for reconsideration before the Commission.
• Petitioners argued that the Court of Appeals erred in applying Department of Justice Administrative Order No. 144, series of 1950.
• Petitioners contended that the Court of Appeals erred in declining to resolve the factual issues they had raised, specifically whether Lozañes' death was due to personal motive/rivalry or because he aided the enemy.

• The Eighth Guerilla Amnesty Commission argued that it lacked jurisdiction because the petitioners did not admit to the crime and because the act was not in furtherance of the resistance movement.
• The Court of Appeals upheld the Commission, stating that an express admission of the crime and the claim that it was committed in furtherance of the resistance movement or against enemy collaborators are necessary for the Amnesty Commission to take cognizance, citing Department of Justice Administrative Order No. 144.
• The Court of Appeals argued that ruling on the factual issues raised by petitioners would be premature, prejudicial, and useless as the case proceeded from the Commission which had no jurisdiction.

• Whether an accused must first admit to the commission of the crime charged to be entitled to the benefits of Amnesty Proclamation No. 8, series of 1946.
• Whether the killing of Amadeo Lozañes fell within the scope of Amnesty Proclamation No. 8, series of 1946, as an act committed in furtherance of the resistance movement or against persons aiding the enemy.
• Whether the Court of Appeals erred in not resolving the factual issues raised by the petitioners concerning the motive for the killing.

• The Supreme Court affirmed the decision of the Court of Appeals, denying the petition.
• The Court held that amnesty presupposes the commission of a crime, and it is inconsistent for an accused to deny committing a crime while simultaneously seeking amnesty for it. Invoking amnesty is akin to a plea of confession and avoidance, meaning the accused admits the allegations but disclaims liability due to intervening facts covered by the amnesty.
• The Court found that the facts established before the Commission did not bring the case within the terms of Amnesty Proclamation No. 8, as the killing of Lozañes was due to rivalry between guerrilla units and not in furtherance of resistance to the enemy, especially since Lozañes himself was part of a recognized guerrilla organization.
• The Court upheld the Court of Appeals' refusal to rule on the factual issues, stating that such a ruling would be premature and useless because the Amnesty Commission, from which the case proceeded, lacked jurisdiction to entertain it due to the petitioners' denial of the crime.

• Amnesty as a Plea of Confession and Avoidance — Amnesty is a public act of oblivion or pardon for past offenses, granted by a government to a class of persons. The Court reiterated that the invocation of amnesty is in the nature of a plea of confession and avoidance, which means the pleader admits the allegations against him but disclaims liability therefor on account of intervening facts (i.e., the act falling under the amnesty proclamation) which, if proved, would bring the crime charged within the scope of the amnesty. In this case, because petitioners denied committing the crime, they could not validly invoke amnesty.
• Conditions for Amnesty under Proclamation No. 8 (1946) — This proclamation extends its benefits to persons who committed any act penalized under the Revised Penal Code in furtherance of the resistance to the enemy or against persons aiding in the war efforts of the enemy. The Court found that the killing of Lozañes, a member of another guerrilla unit, due to inter-unit rivalry, did not meet this condition.
• Jurisdictional Prerequisite for Amnesty Commission — For an Amnesty Commission to take cognizance of a case under the relevant administrative orders (implementing the Proclamation), the accused must allege or claim, verbally or in writing, that they committed the acts charged against them in furtherance of the resistance movement or against persons who aided in the war efforts of the enemy. Since petitioners denied the act, the Commission correctly found it lacked jurisdiction.

• "It is rank inconsistency for appellant to justify an act, or seek forgiveness for an act which, according to him, he has not committed. Amnesty presupposes the commission of a crime, and when an accused maintains that he has not committed a crime, he cannot have any use for amnesty."
• "The invocation of amnesty is in the nature of a. plea of confession and avoidance, which means that the pleader admits the allegations against him but disclaims liability therefor on account of intervening facts which, if proved, would bring the crime charged within the scope of the amnesty proclamation.”

• Barrioquinto, et al. vs. Fernandez, et al. (L-1278, January 21, 1949, 82 Phil. 642) — Cited by petitioners for the proposition that admission of the crime is not a prerequisite for amnesty. The Supreme Court stated this case was superseded.
• Provincial Fiscal of Ilocos Norte vs. De Los Santos, et al. (L-2502, December 1, 1949, 85 Phil. 77) — Cited by petitioners for the same proposition as Barrioquinto. The Supreme Court stated this case was superseded.
• Viray vs. Amnesty Commission, et al. (L-2540, January 28, 1950, 85 Phil. 354) — Cited by petitioners for the same proposition as Barrioquinto. The Supreme Court stated this case was superseded.
• People vs. Llanita, et al. (L-2082, April 26, 1950, 86 Phil. 219) — Cited by the Supreme Court as overruling the Barrioquinto line of cases, establishing that amnesty presupposes the commission of a crime and an accused denying the crime cannot invoke amnesty. This case was followed.
• People vs. Guillermo, et al. (L-2188, May 19, 1950, 86 Phil. 395) — Cited by the Supreme Court alongside Llanita for the same overruling principle. This case was followed.
• Buyco vs. People, et al. (L-6327, July 29, 1954) — Cited by the Supreme Court to reiterate that amnesty cannot be invoked where the accused denies commission of the offense, distinguishing it from petitioners' reliance as it supported the Court's current holding.

• Amnesty Proclamation No. 8, dated September 7, 1946 — This proclamation provides amnesty for persons who committed acts penalized under the Revised Penal Code in furtherance of the resistance to the enemy or against persons aiding in the war effort of the enemy. Its terms were central to determining if petitioners could avail of amnesty.
• Department of Justice Administrative Order No. 144, series of 1950 (amending Administrative Order No. 179, dated November 17, 1949) — This order explicitly directs that "in order that the Amnesty Commission may take cognizance of the case, the accused or respondent must allege or claim verbally or in writing that he committed the acts charged against him in furtherance of the resistance movement or against persons who acted in the war efforts of the enemy." The Court found its application by the Court of Appeals proper as it was issued pursuant to the rulings in Llanita and Guillermo.