People v. Guarin
REITERATIONFacts
The Antecedents: The case involves the crime of adultery. The accused, Patricio C. Guarin, was charged, tried, and convicted along with his paramour, a married woman. Procedural History: The trial court convicted both Guarin and his paramour. After conviction, the married woman was pardoned by the Chief Executive and set at liberty. The Appeal: Guarin appealed his conviction, contending that the pardon granted to his paramour should extinguish his own criminal liability. He based this argument on the prior doctrine under Article 435 of the Penal Code, where remission by the husband of the penalty imposed upon his wife for adultery also remitted the penalty of her paramour. He also cited Article 130 of the Penal Code, which previously classified adultery as a private crime whose criminal liability could be extinguished by the pardon of the offended party.
Issue(s)
Whether the pardon granted by the Chief Executive to the paramour of the appellant in a crime of adultery extinguishes the criminal liability of the appellant. Whether the power of the Chief Executive to pardon is subject to judicial review.
Ruling
The Supreme Court ruled that the pardon granted to the appellant's paramour does not extinguish the appellant's criminal liability. The Court affirmed that the power of the Chief Executive to pardon is absolute and unlimited, and its exercise is not subject to judicial inquiry or review. The judgment of the lower court convicting and sentencing the appellant was affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court held that the pardon granted by the Chief Executive to the appellant's paramour does not extinguish the appellant's criminal liability. The Court explained that prior to Act No. 1773, adultery was considered a private crime, and the husband's remission of penalty could benefit the paramour. However, Act No. 1773 transformed adultery into a public crime, vesting the power to pardon exclusively in the Chief Executive. The Court emphasized that the Chief Executive's power to pardon is unlimited and can be exercised based on various considerations, such as the individual circumstances of the offenders, without necessarily extending to all co-accused. Therefore, the pardon of one offender does not automatically extend to the other. On Issue 2: The Court unequivocally stated that the power to pardon, when exercised by the Chief Executive in favor of persons convicted of public crimes, is unlimited and lies within his absolute and uncontrolled discretion. The reasons for its exercise are not open to judicial inquiry or review. The Court reasoned that the Chief Executive may act without any expressed reason, and it is not the role of the judiciary to question the motives behind the exercise of executive clemency. This principle underscores the separation of powers and the distinct functions of the executive and judicial branches.
Main Doctrine
The Supreme Court affirmed that the pardon power vested in the Chief Executive is absolute and unlimited, meaning its exercise is beyond the scope of judicial review. Consequently, a pardon extended to one of two individuals convicted of adultery does not automatically benefit the other co-offender. This is because, under Act No. 1773, adultery has been classified as a public crime, and the power to pardon offenders rests solely with the Chief Executive, unlike the previous regime where the husband's remission of penalty could affect the paramour's liability.