Friday, August 17, 2018

[CASE DIGEST] People v. Guillen (G.R. No. L-1477)

January 18, 1950 | G.R. No. L-1477

People of the Philippines, plaintiff-appellee
Julio Guillen, defendant-appellant

FACTS:

On March 10, 1947, in an event sponsored by the Liberal Party at Plaza Miranda in Quiapo, Manila, Guillen planted a hand grenade near the stage and threw another one toward then President Manuel Roxas in an apparent assassination attempt born out of Guillen's spite for the President over the latter's perceived failure to fulfill his promises and his call for the passage of the so-called parity measure. General Castaneda managed to kick the grenade off the stage. However, its explosion caused the death of Simeon Varela (Barrela). It also caused the injuries of Alfredo Eva, Jose Fabio, Pedro Carillo, and Emilio Maglalang.

Guillen pleaded not guilty to the consequent charges of murder and multiple frustrated murder filed against him. At one point, he even tried to use the insanity excuse, but he was found to have been mentally stable.

Later on, by his own admission, he confessed to his crimes. He was subsequently found guilty of all the charges and was sentenced to death.

ISSUE:

Whether or not the conviction of the accused was proper.

HELD:

No, the SC ruled that Guillen's actions on March 10, 1947 and their penalties were covered by Art. 48 of the RPC, not sub-section 1 of Art. 49. The Court said that by a single act -- throwing a hand grenade at President Roxas -- he committed two grave felonies:
(a) murder and (b) multiple attempted murder.

At the same time, the murder of Varela was attended by the qualifying circumstance of treachery, given that the victim was not able to put up a defense against the attack, even though he was not the principal target.

And lastly, the Court ruled that the injuries sustained by the other victims constitute attempted and not frustrated murder. The Court reasoned that Guillen's failed attempt to kill President Roxas was due to some reason or accident (General kicking the grenade off the stage) other than his own spontaneous desistance.

In the end the Court affirmed the death sentence handed out by the lower court.

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Art. 48, RPC: "Penalty for complex crimes -- When a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means for committing the other, the penalty for the most serious crime shall be imposed, the same to be applied in its maximum period."