FACTS:

The case involves an appeal from a decision by the Regional Trial Court of Trece Martires, Cavite, finding the accused guilty of illegal possession of firearms in violation of Presidential Decree No. 1866. The accused, Santiago Evaristo and Noli Carillo, were charged with manufacturing, repairing, and keeping firearms without a permit or license.

According to the prosecution's witnesses, a police patrol heard bursts of gunfire and encountered a man firing a gun into the air. The man fled to Evaristo's house, where the slightly intoxicated appellants were found. Upon frisking Carillo, a bulge was noticed around his waist, and he admitted it was a .38 revolver.

As Carillo did not have a valid license to possess the firearm, it was confiscated, and Carillo was invited for questioning. The police officers sought permission from Evaristo to search the house, and they discovered firearms and paraphernalia used for the repair and manufacture of firearms.

The appellants denied ownership or knowledge of the firearms, alleging that they were forcibly taken into custody and that the firearms were planted by the prosecution witnesses and other police authorities. The trial court found the appellants guilty of illegal possession of firearms and sentenced them to life imprisonment.

The appellants raised the issue of illegal search and seizure as errors of the trial court.

ISSUES:

1. Whether the firearms seized from the appellants were illegally obtained.

2. Whether the firearms seized from the appellants fall under the definition of firearms as contemplated in Presidential Decree No. 1866.

3. Whether the testimonies of the arresting officers should be given credence despite alleged contradictions and half-truths.

RULING:

1. The court held that the firearms seized from the appellants were not illegally obtained. The search conducted was not unreasonable and in violation of the constitutional right against unreasonable searches and seizures. The police officers had probable cause to search the premises based on the bursts of gunfire and the pursuit of an armed individual leading to the house of the appellants.

2. The court ruled that the firearms seized from the appellants fall under the definition of firearms as contemplated in Presidential Decree No. 1866. The firearms and paraphernalia found in the house were classified as firearms and used for the manufacture and repair of firearms. This falls within the scope of the law prohibiting illegal possession of firearms.

3. The court upheld the credibility of the testimonies of the arresting officers. Alleged contradictions and half-truths in their testimonies do not necessarily render their testimonies wholly unreliable. Inconsistencies in testimonies are common and do not automatically undermine the credibility of the witnesses. The court found that the testimonies of the arresting officers were sufficient to establish the guilt of the appellants beyond reasonable doubt.

PRINCIPLES:

• The right to be secure in one's person, house, papers, and effects against unreasonable searches and seizures is guaranteed by Article III of the Constitution.

• A search conducted without a warrant may still be valid if there is probable cause and the search falls under one of the recognized exceptions to the warrant requirement.

• The definition of firearms under the law should be interpreted broadly to encompass not only complete firearms but also parts, components, accessories, and paraphernalia used for the manufacture and repair thereof.

• Inconsistencies or contradictions in the testimonies of witnesses do not automatically undermine their credibility, and the court may still give credence to their testimonies if they are found to contain substantial truth and accord with common sense and human experience.