People v. De Guzman
REITERATIONFacts
The Antecedents: Petitioner Ruben De Guzman y Lazano (Ruben) was charged with violation of Presidential Decree No. (PD) 1866, as amended by Republic Act No. (R.A.) 8294, for allegedly possessing an unlicensed M16 Baby Armalite with magazine and seventeen (17) rounds of live ammunition outside his residence without the necessary license or permit. Procedural History: The Regional Trial Court (RTC) of Tuguegarao City, Branch 1, found Ruben guilty beyond reasonable doubt and sentenced him to suffer imprisonment of six (6) years and one (1) day to eight (8) years, and to pay a fine of P30,000.00. The RTC gave weight to the testimonies of prosecution witnesses Dionisio Jarquio and Ramil Pajar, who testified that Ruben had the firearm and grappled for it. The RTC also noted that Ruben did not categorically deny ownership or possession and did not present evidence to support his claim of ill-will against Dionisio. The Court of Appeals (CA) affirmed the RTC's decision with modification, sentencing Ruben to four (4) years, two (2) months and one (1) day of prision correccional, as minimum, to seven (7) years of prision mayor, as maximum, finding that all elements of the crime were proven. The Petition: Ruben filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision. He argued that the prosecution witnesses' testimonies were not credible, that the firearm was not properly identified and marked, and that animus possidendi was not established. He presented his own account, corroborated by defense witnesses, that he was attacked by Dionisio and others, and that he sustained injuries, which were medically confirmed.
Issue(s)
Whether the Court of Appeals erred in affirming the conviction of Ruben for violating PD 1866, specifically regarding the element of possession of an unlicensed firearm. Whether the prosecution sufficiently proved that the accused possessed the unlicensed firearm. Whether the element of animus possidendi was established beyond reasonable doubt. Whether the lower courts erred in assessing the credibility of witnesses and evidence presented by both the prosecution and the defense. Whether the prosecution established Ruben's guilt beyond reasonable doubt.
Ruling
The petition is GRANTED. The Decision dated December 14, 2018 and the Resolution dated July 8, 2019 of the Court of Appeals in CA-G.R. CR No. 40111 are REVERSED and SET ASIDE. Petitioner Ruben De Guzman y Lazano is ACQUITTED of the crime charged against him.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the conviction of Ruben for violating PD 1866, specifically regarding the element of possession of an unlicensed firearm: The Supreme Court found that the prosecution failed to prove beyond reasonable doubt that Ruben was in possession of the subject firearm. The Court gave more credence to Ruben's account, supported by defense witnesses Silverio Severo and Felisa Zingapan, and medical findings from Dr. Ram by Danao, which indicated that Ruben was mauled and sustained a lacerated wound. The testimonies of prosecution witnesses Dionisio Jarquio and Ramil Pajar, who claimed Ruben had the firearm and grappled for it, were found less credible. The Court noted that Silverio and Felisa, who are disinterested parties, did not see Ruben with a firearm on the day of the incident. The Court also found that the testimonies of PO1 Callueng and SPO3 Calimag could not be given weight as they relied on reports and arrested Ruben without verification. Therefore, the essential element of possession was not sufficiently established. On the issue of whether the prosecution sufficiently proved possession of the unlicensed firearm: The Supreme Court found that the prosecution failed to prove beyond reasonable doubt that Ruben was in possession of the subject firearm. The Court gave more credence to Ruben's account, supported by defense witnesses Silverio Severo and Felisa Zingapan, and medical findings from Dr. Ram by Danao, which indicated that Ruben was mauled and sustained a lacerated wound. The testimonies of prosecution witnesses Dionisio Jarquio and Ramil Pajar, who claimed Ruben had the firearm and grappled for it, were found less credible. The Court noted that Silverio and Felisa, who are disinterested parties, did not see Ruben with a firearm on the day of the incident. The Court also found that the testimonies of PO1 Callueng and SPO3 Calimag could not be given weight as they relied on reports and arrested Ruben without verification. Therefore, the essential element of possession was not sufficiently established. On the issue of animus possidendi: While the existence of the firearm and its unlicensed status were not disputed, the Court's finding that Ruben was not in possession of the firearm rendered the issue of animus possidendi moot. The Court emphasized that possession must be coupled with animus possidendi, which is an intent to possess. Since the primary element of possession was not proven, the intent to possess could not have been established. The Court also noted that Ruben's account of being attacked and injured, supported by medical findings, contradicted the prosecution's narrative of him possessing and grappling for the firearm. The defense witnesses, who were not related to Ruben, corroborated his version of events, casting doubt on the prosecution's claims. On the credibility of witnesses and evidence: The Supreme Court reiterated that while factual findings of the RTC, especially when affirmed by the CA, are generally respected, it will review such findings if there are facts or circumstances of weight that were overlooked, misapprehended, or misinterpreted. In this case, the Court found that the lower courts erred in relying on the testimonies of Dionisio and Ramil and in disregarding the defense witnesses' testimonies and the medical findings. The Court highlighted that Silverio and Felisa, who were not related to Ruben, provided accounts that were more consistent with Ruben's injuries and his claim of being attacked. The Court also found issues with the testimonies of the police officers, who relied on reports without independent verification. Consequently, the evidence presented by the prosecution was deemed insufficient to establish Ruben's guilt beyond reasonable doubt. On the issue of whether the prosecution established Ruben's guilt beyond reasonable doubt: The Supreme Court found that the prosecution failed to prove beyond reasonable doubt that Ruben was in possession of the subject firearm. The Court gave more credence to Ruben's account, supported by defense witnesses Silverio Severo and Felisa Zingapan, and medical findings from Dr. Ram by Danao, which indicated that Ruben was mauled and sustained a lacerated wound. The testimonies of prosecution witnesses Dionisio Jarquio and Ramil Pajar, who claimed Ruben had the firearm and grappled for it, were found less credible. The Court noted that Silverio and Felisa, who are disinterested parties, did not see Ruben with a firearm on the day of the incident. The Court also found that the testimonies of PO1 Callueng and SPO3 Calimag could not be given weight as they relied on reports and arrested Ruben without verification. Consequently, the evidence presented by the prosecution was deemed insufficient to establish Ruben's guilt beyond reasonable doubt.
Main Doctrine
The prosecution failed to prove beyond reasonable doubt that the accused was in possession of the unlicensed firearm, as the accused's account of being mauled and the corroborating testimonies of defense witnesses were found to be more credible than the prosecution's witnesses. Therefore, the accused must be acquitted.