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G.R. No.

L - 1477
January 18, 1950
People vs. Guillen

Issues:
Whether or not the appellant is guilty of murder for the death of Simeon Varela
Whether or not the appellant is guilty of the complex crime of murder and multiple
frustrated murder
Whether or not sub-section 1 of Article 49 of the RPC in the determining the penalty
to be imposed upon the accused
Whether or not the concurrence of the aggravating circumstances of nocturnity and
of contempt of public authorities in the commission of the crime should be
considered

Ruling:
Facts do not support the contention of the counsel for the appellant that he is guilty
only of homicide through reckless imprudence in regard to the death of Simeon
Varela and of less physical injuries in regard to other victims
In throwing the hand grenade at the President with the intention of killing him, the
appellant acted with malice and is therefore liable for all the consequences of his
wrongful act
As provided by Art. 4 of the Revised Penal Code, criminal liability is incurred by any
person committing a felony although the wrongful act done be different from that
which he intended
A In criminal negligence, the injury caused to another should be unintentional, it
being simply the incident of another act performed without malice
As held by the Court, a deliberate intent to do an unlawful act is essentially
inconsistent with the idea of reckless imprudence.
Where such unlawful act is willfully done, a mistake in the identity of the intended
victim cannot be considered reckless imprudence
The sentence of the trial court is affirmed by unanimous vote and death sentence
shall be executed in accordance with article 81 of the Revised Penal Code

Facts:
Julio Guillen Y Corpus, had the opportunity to assassinate President Manuel A. Roxas
on the night of March 10, 1947 at a popular meeting held by the Liberal Party at
Plaza de Miranda, Quiapo, Manila
Guillen had voted for the defeated candidate in the presidential elections held in
1946 in which Manuel A. Roxas is the successful candidate
Guillen became disappointed in President Roxas for his alleged failure to redeem the
pledges and fulfill his promises
Also, President Roxas sponsored and campaigned for the approval of the so-called
parity measure that caused Guillens disappointment to aggravate
Guillen had first intended to use a licensed revolver but having it lost, he thought of
two hand grenades
Morning at the same date, he went to the house of Amado Hernandez whom he
requested to prepare for him a document (his last will) and handed it to him only at
about 6:00 in the afternoon, which appears unsigned (but subsequently signed in
the police headquarters after the incident)
When Guillen reached the said venue, he was carrying a concealed paper bag which
contained his two hand grenades and peanuts
He buried one of the grenades in a plant pot located close to the platform, while he
hurled the other one at the President
General Castaeda kicked it away from the platform towards an open space when it
caught his attention, and had then exploded in the middle of a group of persons
where Simeon Varela belongs
Simeon Varela died on the following day as a result of mortal wounds
Guillen did not feel guilty in killing other people present in the event in order to
attain his main purpose of killing the president
Art. 48. 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.