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Case Digest of People Vs Geronimo 100 Phil 90

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People vs Geronimo

100 Phil 90

Facts:

 Federico “Commander Oscar” Geronimo et., al. were charge for complex rebellion with murders,
robberies, and kidnapping.
 Communist Party of the Philippines (CPP), Hukbong Mapagpalaya Ng Bayan (HMB) or otherwise
known as the Hukbalahaps (HUKS) having come to an agreement and decided to commit the crime of
Rebellion and conspiring together.
 Members of the HUKS attack the Party of Mrs. Aurora A. Quezon and her PC escort whom they
resulting in the killing of Mrs. Aurora A. Quezon, Baby Quezon, Mayor Bernardo of Quezon City, Major
P. San Agustin, Lieutenant Lasam, Philip Buencamino III, and several soldiers and the wounding of
General Jalandoni and Captain Manalang.
 Members of the Hukbong Mapagpalaya Ng Bayan (HMBS) feloniously and forcibly bringing the Cashier
of the Provincial Treasury, Mr. Vicente Reventar from his house to the Provincial Capitol and at the
point of guns forced him to open the Treasury Vault and took therefrom Eighty Thousand Pesos
(P80,000)
 Members of the HUKS raided the house of one Nemesio Palo, a police sergeant of Libmanan,
Camarines Sur and killed the said officer.
 Commander Oscar ambushed and fired upon an Army Patrol headed by Cpl. Bayrante, resulting in
seriously wounding of Pfc. Paneracio Torrado and Eusebio Gruta a civilian.
 Commander Oscar with evident premeditation, willfully, unlawfully and feloniously killed one
Policarpio Tipay a barrio lieutenant.
 Federico Geronimo first entered a plea of not guilty to the information and later on he asked the
permission of the court to substitute his original plea with one of guilty
 Fiscal recommended that the penalty of life imprisonment be imposed upon the accused, his
voluntary plea of guilty being considered as a mitigating circumstance.
 Geronimo’s counsel argued that the penalty imposable was only prision mayor, because there is no
such thing as complex crime as rebellion with murders, robberies, and kidnapping are natural
consequence of rebellion. The crime charged against the accused should be considered only as simple
rebellion.
Issue:
 Whether or not the crime committed by Federico “Commander Oscar” Geronimo et. al. is a complex
crime of rebellion with murders, robberies, and kidnappings.
Ruling:

No, The court ruled that it is a simple rebellion. Not every act of violence is to be deemed absorbed in the
crime of rebellion solely because it happens to be committed simultaneously with or in the course of the
rebellion. If the killing, robbing, etc. were done for private purposes or profit, without any political motivation,
the crime would be separately punishable and would not be absorbed by the rebellion. But even then, the
individual misdeed could not be taken with the rebellion to constitute a complex crime, for the constitutive
acts and intent would be unrelated to each other; and the individual crime would not be a means necessary for
committing the rebellion, as it would not be done in preparation or in furtherance of the latter.

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