PEOPLE vs GUILLEN

January 18, 1950 | G.R. No. L-1477

People of the Philippines, plaintiff-appellee

Julio Guillen, defendant-appellant

FACTS:

On March 10, 1947, in an event sponsored by the Liberal Party at Plaza Miranda in Quiapo, Manila, Guillen planted
a hand grenade near the stage and threw another one toward then President Manuel Roxas in an apparent
assassination attempt born out of Guillen's spite for the President over the latter's perceived failure to fulfill his
promises and his call for the passage of the so-called parity measure. General Castaneda managed to kick the
grenade off the stage. However, its explosion caused the death of Simeon Varela (Barrela). It also caused the injuries
of Alfredo Eva, Jose Fabio, Pedro Carillo, and Emilio Maglalang.

Guillen pleaded not guilty to the consequent charges of murder and multiple frustrated murder filed against him. At
one point, he even tried to use the insanity excuse, but he was found to have been mentally stable. 

Later on, by his own admission, he confessed to his crimes. He was subsequently found guilty of all the charges and
was sentenced to death.

ISSUE:

Whether or not the conviction of the accused was proper.

HELD:

No, the SC ruled that Guillen's actions on March 10, 1947 and their penalties were covered by Art. 48 of the RPC,
not sub-section 1 of Art. 49. The Court said that by a single act -- throwing a hand grenade at President Roxas -- he
committed two grave felonies:
(a) murder and (b) multiple attempted murder.