Case Summary (G.R. No. L-1477)
Procedural History
Guillen was arraigned before the Court of First Instance of Manila (Case No. 2764), pleaded not guilty, and was tried by Judge Buenaventura Ocampo. He was convicted of murder and multiple frustrated murder, sentenced to death, ordered to indemnify Varela’s heirs ₱2,000, and charged court costs. The conviction was appealed directly to the Supreme Court.
Mental Condition Examination
Prior to trial, court-appointed experts confined Guillen at the National Psychopathic Hospital for eight days. Their unanimous report found no insanity but diagnosed “constitutional psychopathic inferiority” without psychosis. A defense expert dissented, yet the trial court ruled Guillen competent to stand trial.
Factual Background
Guillen, disappointed by President Roxas’s post‐election policies—particularly the proposed parity amendment—resolved to assassinate him. After losing his licensed revolver, he retained two hand grenades acquired during Manila’s liberation. He planned the attack for the Liberal Party’s Plaza de Miranda rally.
Evidence and Admissions
• Exhibit B: A Tagalog “last will” authored by Guillen, expressing personal responsibility and patriotic motive.
• At approximately 7 m from the platform, Guillen threw one grenade as Roxas concluded his speech. General Castaneda deflected it, saving the President but wounding bystanders.
• Guillen was identified within two hours by witnesses Angel Garcia and Manuel Robles, arrested at home, and gave a consistent voluntary statement. He reenacted the crime and pointed out the hidden second grenade.
Legal Issues
- Whether the killing of Varela constituted murder rather than homicide by reckless imprudence.
- Whether the simultaneous acts amounted to a complex crime of murder and multiple frustrated murder.
- Whether Article 49(1) of the Revised Penal Code was properly applied in fixing the penalty.
- Whether aggravating circumstances (nocturnity, contempt of public authority) were correctly considered.
Analysis on Malice and Criminal Liability
By deliberately throwing an explosive device at the President, Guillen acted with malice and foresaw harm to surrounding persons. Under Article 4 RPC, intent to kill extends criminal liability to unintended victims. Reckless imprudence is inapplicable when there is a deliberate intent to kill.
Application of Complex Crime Doctrine
The single act of throwing a hand grenade produced two grave felonies: (1) murder of Varela; (2) multiple attempted murders of Roxas and four bystanders. This falls squarely under Article 48 RPC, which mandates imposing the penalty for the most serious crim
...continue readingCase Syllabus (G.R. No. L-1477)
Procedural History
- The Court of First Instance of Manila (Case No. 2764) tried Julio Guillen y Corpus on charges of murder and multiple frustrated murder.
- Upon arraignment, the accused pleaded not guilty.
- After the prosecution and defense evidence, the trial court, presided over by Hon. Buenaventura Ocampo, found the accused guilty beyond reasonable doubt.
- The trial court imposed the penalty of death, ordered indemnity of ₱2,000,000 to the heirs of the deceased Simeon Varela (Barrela), and the payment of costs.
- The accused appealed to the Supreme Court, which reviews the judgment per curiam.
Mental Examination and Sanity Determination
- Before arraignment, counsel de oficio moved for psychiatric evaluation of the accused’s mental condition.
- Initial court questions revealed no mental derangement; nevertheless, the court ordered an eight-day confinement at the National Psychopathic Hospital.
- A medical board, presided by Dr. Fernandez, conducted constant observation, administered narco-synthesis, and ruled the accused not insane.
- The board’s “Formulation and Diagnosis” concluded:
• No sign or symptom of insanity; the accused could distinguish right from wrong.
• Truthfulness of his motivation was confirmed by successful narco-synthesis without evidence of delusions or hallucinations.
• He exhibited strong will, impulsiveness, and a personality defect labeled “Constitutional Psychopathic Inferiority,” but no psychosis. - A dissenting opinion by Dr. Alvarez for the defense was overruled; the court found the accused sane and fit to stand trial.
Material Facts of the Offense
- Political Context and Motive:
• In the 1946 presidential election, Guillen voted for the defeated Roxas opponent.
• He felt betrayed by President Roxas’s unfulfilled promises and sponsorship of the “parity” measure.
• He resolved to assassinate the President as a patriotic duty. - Choice and Preparation of Weapon:
• Having lost his licensed revolver, Guillen acquired two hand grenades f