**Facts:**
1. **Incident of Assault**:
– On March 10, 1947, during a political rally at Plaza de Miranda, Quiapo, Manila, Julio Guillen, driven by political disappointment in President Manuel Roxas, decided to assassinate the president.
– Guillen had two hand grenades given to him by an American soldier during the early days of the liberation of Manila. These grenades were hidden in a paper bag along with peanuts.
– During President Roxas’s speech, Guillen stood on a chair approximately seven meters from the platform and threw one of the grenades aiming at the President. General Castañeda saw the grenade and deflected it, shouting for the crowd to take cover. The grenade exploded, injuring multiple people and ultimately killing Simeon Varela.
2. **Capture and Confession**:
– Guillen was seen fleeing the scene by a witness, Angel Garcia, who attempted to stop him but Guillen resisted and managed to escape.
– Within two hours after the blast, based on witness statements and investigative leads, Guillen was apprehended at his home.
– Guillen admitted to throwing the grenade and explained his motive, which was political dissatisfaction.
3. **Mental Evaluation**:
– Before trial, Guillen’s lawyer requested a mental evaluation. The court ordered Guillen’s confinement in the government Psychopathic Hospital where he was examined.
– The examiners concluded that Guillen was not insane but was diagnosed with “Constitutional Psychopathic Inferiority” without psychosis.
4. **Trial**:
– Julio Guillen was tried in the Court of First Instance of Manila, where he pleaded not guilty.
– Despite arguments from the defense regarding his mental state, he was found guilty of murder and multiple counts of frustrated murder and sentenced to death.
**Issues:**
1. **Determination of Guilt in the Case of Simeon Varela’s Death**:
– Was Guillen guilty of murder or was it a lesser crime such as homicide through reckless imprudence?
2. **Complex Crime and Multiple Attempted Murders**:
– Did Guillen commit a complex crime of murder and multiple frustrated murders, and what should be the appropriate penalty?
3. **Application of Article 49 of the Revised Penal Code**:
– Should Article 49 of the Revised Penal Code be applied, which deals with the penalty for the most serious crime in cases where a single act constitutes multiple felonies?
4. **Aggravating Circumstances**:
– Were there aggravating circumstances present, specifically nocturnity and contempt of public authorities, that should influence the sentence?
**Court’s Decision:**
1. **Murder Conviction**:
– The Court confirmed Guillen was guilty of murder for the death of Simeon Varela. It determined that his actions were deliberate and intentional, intended to cause harm not only to President Roxas but also to those around him.
2. **Complex Crime**:
– The Court declared Guillen’s act as constituting a complex crime of murder and multiple attempted murders. Article 48 of the Revised Penal Code applied, as his single act resulted in multiple grave felonies.
3. **Applicability of Article 49**:
– Article 49 was found not applicable. Instead, Article 48 was applied, demanding the penalty for the most serious felony (murder) be imposed in its maximum period due to the complex crime nature.
4. **Aggravating Circumstances**:
– While there were noted aggravating circumstances (night-time and an attack against public authorities), the necessity to consider them was deemed redundant under Article 48, which prescribes the penalty in its maximum term in complex crime cases.
**Doctrine:**
– **Principle of Complex Crimes**:
– Article 48 of the Revised Penal Code governs situations where one act leads to several serious felonies, demanding the most severe penalty be applied to its fullest extent.
– **Criminal Intent and Liability**:
– A deliberate intent to commit an unlawful act, where resultant harm can be anticipated, does not give rise to charges of recklessness but a direct liability for resulting crimes.
– **Immateriality of Motive Under Malice**:
– The presence of aggravating circumstances can elevate the severity of punishment but, in cases under Article 48, the maximum punishment for the gravest charge must be applied regardless.
**Class Notes:**
– **Complex Crimes**: Defined under Article 48, where one act leads to multiple grave felonies.
– **Aggravating Circumstances**: Factors like nocturnity and contempt of public authorities that increase the severity of a crime’s punishment.
– **Criminal Intention**: As per Article 4 of the Revised Penal Code, intent to commit harm leads to direct felony charges, bypassing reckless imprudence classifications.
– **Mental Health and Criminal Responsibility**: Diminished insanity while still being able to distinguish right from wrong, as per diagnostic psychiatric evaluations.
**Historical Background:**
– Post-WWII Philippine political atmosphere, with increased scrutiny on public promises and leadership.
– The assassination attempt on President Roxas reflected deep political unrest during the formative years of the Republic of the Philippines.
– This case highlights early legal principles dealing with political violence and assassination attempts in the Philippines, laying down precedents for future legal action against politically motivated crimes.
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