People V Geronimo, Et Al. (1956) Facts

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People v Geronimo, et al.

(1956) - Violate the fundamental rule that all doubts should be resolved in
favor of the accused
Facts: - Even if the acts were done without any political motivation and cannot be
- Federico Geronimo, together with others, are officers or members of the Communist absorbed by rebellion, there still wouldn’t be a complex crime because the
Party of the Philippines and the HUKS acts and intent would be unrelated to each other
- They supported, maintained, and commanded the HUKS to rise publicly and take - EFFECT OF GERONIMO’S PLEA OF GUILTY:
arms against the government - 6 Justices Opinion: The accused has admitted all the acts
- The means: Raids, attacks against the Philippine Constabulary, the civilian described in the information, and if any of the acts are determined
guards, the police and the army; Murder, pillaging, looting, plunder, to be independent of rebellion, then he will be convicted of those
kidnapping and destruction of property crimes separately
- Attacked and fired upon the party of Mrs. Aurora, killing them - The killing of Policarpio Tibay is an independent crime
- Forcibly bringing the cashier of the Provincial Treasury, and at the not politically motivated so this will be punished
point of guns forced him to open the Treasury separately
- Raided the house of Nemesio Palo, a police sergeant, captured - 5 Justices Opinion: The accused has only admitted to the acts as
him then killed him being part of the rebellion, since that is what the prosecution
- Seriously wounded Pfc. Paneracio Torrado and others charged against him. Hence, he may only be convicted of simple
- Killed one Policarpio Tipay rebellion
- The prosecution charged them with the complex crime of rebellion with murders,
robberies, and kidnapping Conclusion:
- Federico Geronimo entered a plea of guilty, but argued that there is no such thing as - Geronimo is convicted of the simple crime of rebellion (8 yrs prision mayor & P10,000
the complex crime of rebellion with murder, robbery, and kidnapping. fine) and also for the crime of murder (not less than 10 yrs and 1 day of prision mayor
- He argued that he should only be charged with simple rebellion and not more than 18 yrs of reclusion temporal) with the mitigating circumstance of
- The Trial Court found the accused guilty of the complex crime aforementioned voluntary plea of guilty
(reclusion perpetua) with the mitigating circumstance of voluntary plea of guilty

Issue:
- WoN the crime committed by Geronimo is simple rebellion or the complex crime of
rebellion with murder, robbery, and kidnapping

Held:
- Only simple rebellion, following the Hernandez doctrine
- Any or all of the acts described in Article 135, when committed as a means
to or in furtherance of the subversive ends described in Article 134, become
absorbed in the crime of rebellion
- However, these acts must be committed for political ends or in
furtherance of the rebellion
- The acts in the information all come within the acts listed in Article 135
- Ambushing and firing upon army patrol = engaging in combat with
loyal troops
- Taking funds and equipment from the Provincial Treasury of
Laguna = diverting public funds from their legitimate purpose
- Killings of people = serious violence
- The reason why rebellion, even if absorbing murder, is punishable by a
lesser penalty, is because of the political purpose that impels every
rebellious act
- And our history of three centuries of uninterrupted rebellions
against sovereign Spain, until she was finally driven from our
shores, suffices to explain why the penalty is the way it is
- Complexing the crime of rebellion would lead to these undesirable results
- Punishment for rebellion heavier than treason
- Rebel followers and leaders would be punished the same

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