G.R. No. L-1477 - People vs. Guillen

This is an appeal from the Court of First Instance of Manila (Case No. 2764) where Julio Guillen y Corpus was found guilty beyond reasonable doubt of murder and multiple frustrated murder. He was sentenced to death, ordered to indemnify the heirs of the deceased Simeon Varela in the sum of ₱2,000, and to pay costs.
Upon arraignment, the accused pleaded not guilty. Before trial, counsel de oficio moved for a psychiatric examination. After an eight-day confinement at the National Psychopathic Hospital and evaluation by a medical board, Guillen was found sane (diagnosed with “constitutional psychopathic inferiority, without psychosis”) and the trial proceeded under Judge Buenaventura Ocampo.

Guillen, disappointed in President Manuel A. Roxas for alleged unfulfilled campaign promises and promotion of the “parity” amendment, resolved to assassinate him.
Having lost his licensed revolver, he acquired two hand grenades from an American soldier in exchange for whiskey.

On March 10, 1947, Guillen drafted a “last will” (Exhs. B, B-1, B-2) expressing sole responsibility for the act and declaring it a patriotic duty.
He carried the two grenades hidden in a paper bag with peanuts, buried one in a plant pot near the platform at Plaza Miranda, Quiapo, Manila, and kept the other ready to throw.

At a Liberal Party rally where President Roxas was speaking, Guillen stood on a chair about seven meters from the platform and hurled the grenade as Roxas finished his speech.
General Castaneda, on the platform, kicked the smoking grenade down the stairs into an open space; it exploded, causing panic.

Simeon Varela (or Barrela) suffered mortal wounds from shrapnel and died the following day.
Alfredo Eva, Jose Fabio, Pedro Carrillo, and Emilio Maglalang were seriously wounded by grenade fragments.

Eyewitness Angel Garcia chased the thrower but initially detained another man; Manuel Robles correctly identified Guillen as the culprit.
Within two hours Guillen was arrested at his home (1724 Juan Luna Street, Manila). He voluntarily admitted responsibility, revealed the hidden grenade and manifesto, reenacted the crime (Exh. C, C-1), and signed a sworn statement (Exh. E) consistent with his trial testimony.

Whether the trial court erred in finding the appellant guilty of murder for the death of Simeon Varela.
Whether the court erred in declaring the appellant guilty of the complex crime of murder and multiple frustrated murder.
Whether the court improperly applied subsection 1 of Article 49 of the Revised Penal Code in determining the penalty.
Whether the court erroneously considered the aggravating circumstances of nocturnity and contempt of public authorities.