G.R. No. L-1477; January 18, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JULIO GUILLEN, defendant-appellant.

FACTS

The accused, Julio Guillen, was charged with murder and multiple frustrated murder. Motivated by political disappointment with President Manuel Roxas over the “parity” amendment issue, Guillen planned to assassinate the President. On the night of March 10, 1947, during a pro-parity rally at Plaza Miranda attended by President Roxas, Guillen threw a hand grenade at the platform. The grenade exploded, killing Simeon Valera (or Barrela) and injuring several others, but President Roxas was unharmed. Before the trial, the court ordered a mental examination of Guillen. A medical board diagnosed him with “Constitutional Psychopathic Inferiority” but found him not insane, legally sane, and fully aware of the nature and consequences of his act.

ISSUE

Whether the trial court correctly convicted Julio Guillen of the complex crime of murder and multiple attempted murder.

RULING

Yes, the Supreme Court affirmed the conviction and the imposition of the death penalty. The Court held that Guillen committed the complex crime of murder and multiple attempted murder through a single act of throwing a hand grenade. The killing of Simeon Valera constituted murder qualified by treachery, as the attack was sudden and unexpected, giving the victim no opportunity to defend himself. The injuries to others constituted attempted murder, as the intent to kill was evident but the victims survived due to causes independent of Guillen’s will. The aggravating circumstance of evident premeditation was present in the intent to kill President Roxas. The Court found no mitigating circumstances and upheld the penalty of death, applying Article 48 of the Revised Penal Code, which mandates the penalty for the most serious crime (murder) in its maximum period. The mental examination’s finding that Guillen was not legally insane was upheld, making him fully criminally liable.

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