People v. Villasco
REITERATIONFacts
The Antecedents: On September 27, 1950, Pascasio Villasco and three others were charged with illegal possession of firearms and a hand grenade, allegedly committed on July 19, 1950. The information specified five items: two U.S. Garand rifles, two Eddystone rifles, and one hand grenade, allegedly possessed without the necessary permit or license, contrary to Section 2692 of the Revised Administrative Code, as amended by Republic Act No. 4. Procedural History: Upon motion of the prosecution, the charges against the three co-accused were dismissed. Before trial, Pascasio Villasco moved to quash the information, arguing it did not plead facts constituting a violation of the cited law. The motion was denied. Villasco then pleaded not guilty, but subsequently moved to withdraw his plea and enter a plea of guilty. The court sentenced him to five years imprisonment and to pay costs. A motion for reconsideration was denied, leading to this appeal. The Petition: The appellant, Pascasio Villasco, appealed the sentence. Both his counsel and the Solicitor General recommended reversal and acquittal, contending that the information failed to allege the circumstances under which the firearms and hand grenade were seized, specifically whether the appellant was using or carrying them at the time of seizure.
Issue(s)
Whether an Information for illegal possession of firearms is sufficient if it fails to allege that the accused used or carried the weapons during the one-year surrender period provided by Republic Act No. 482. Whether a plea of guilty by the accused admits the commission of a crime if the Information itself does not allege facts sufficient to constitute a public offense.
Ruling
The judgment is reversed, and the appellant is acquitted, with costs de officio.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Information was insufficient because it failed to state all the necessary elements of the offense as modified by the prevailing amnesty law. Under Section 1 of Republic Act No. 482, the mere possession of firearms was temporarily legalized for the purpose of allowing citizens to surrender them within one year from June 10, 1950. The law specified that criminal liability would only attach if the possessor was found 'making use of' the firearm or 'carrying them on his person' for purposes other than surrender. In the present case, the Information merely alleged that Villasco had the weapons in his 'possession and under [his] custody and control' on July 19, 1950, which fell within the one-year surrender window. Applying the rule from People v. Santos Lopez y Jacinto, the Court emphasized that the use or carrying of firearms was an essential ingredient of the offense during the statutory period. Since these specific acts were not alleged in the Information, the prosecution failed to describe a punishable act under the law. On Issue 2: The Court held that a plea of guilty does not admit the commission of a crime if the underlying Information is legally insufficient. A plea of guilty functions as an admission of the facts set out in the Information; however, if those facts do not constitute a crime or a violation of law, the plea cannot create a criminal liability where none exists. The Court clarified that a plea of guilty does not have the effect of 'supplying what has been omitted' or curing a defective Information that fails to allege facts sufficient to constitute a public offense. Citing People v. Aquino y Abalos, the Court reiterated that the law and the presidential proclamation by necessary inference legalized mere possession during the surrender period. Because the appellant was charged only with possession during a time when possession alone was not illegal, his subsequent plea of guilty did not constitute a valid admission of a crime, necessitating his acquittal.
Main Doctrine
A plea of guilty admits the facts alleged in the information. If these facts do not constitute a crime or a violation of law, the plea does not admit the commission of a crime or supply deficiencies in the information.