ENRILE vs. AMIN component element or committed in furtherance of rebellion.

All crimes, whether

punishable under a special law or general law, which are mere components or
G.R. No. 93335, September 13, 1990 ingredients, or committed in furtherance thereof, become absorbed in the crime
of rebellion and cannot be isolated and charged as separate crimes in themselves.
Doctrines:

Rebellion; crimes absorbed.— Acts committed in furtherance of the rebellion though

crimes in themselves are deemed absorbed in the one single crime of rebellion. All
crimes, whether punishable under a special law or general law, which are mere
components or ingredients, or committed in furtherance thereof, become absorbed in
the crime of rebellion and cannot be isolated and charged as separate crimes in
themselves.

Political crimes.— Political crimes are those directly aimed against the political order,
as well as such common crimes as may be committed to achieve a political purpose.
The decisive factor is the intent or motive.

Facts:

1. An information was filed against Sen. Juan Ponce Enrile for having
committed Rebellion complexed with Murder with the RTC of Quezon City.
2. Another information was subsequently filed with the RTC of Makati,
charging Enrile of violating P.D. No. 1829 for willfully and knowingly
obstructing or delaying the apprehension of Ex-Col. Gregorio “Gringo”
Honasan.
3. Allegedly, Enrile entertained and accommodated Honasan by giving him
food and comfort in 1 December 1989 in his house. Knowing that Col.
Honasan is a fugitive from justice, Enrile allegedly did not do anything to
have Honasan arrested or apprehended.

Issue: Whether Enrile can be separately charged for violation of P.D. No. 1829
notwithstanding the rebellion case earlier filed against him

Ruling: No, Enrile cannot be separately charged for violation of P.D. No. 1829.
The violation of P.D. 1892 is absorbed in the crime of rebellion.

The Court stated that People v. Hernandez remains the binding doctrine operating
to prohibit the complexing of rebellion with any other offense committed on the
occasion thereof, either as a means to its commission or as an unintended effect
of an activity that commutes rebellion. If a person cannot be charged with the
complex crime of rebellion for the greater penalty to be applied, neither can he be
charged separately for two (2) different offenses where one is a constitutive or