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ARNULFO v. PEOPLE

FACTS:

The petitioner was charged with illegal possession of firearms and ammunition under Presidential Decree (PD) No. 1866, as amended by Republic Act (RA) 8294. A search warrant was issued and implemented at the petitioner's residence. During the search, several firearms and ammunitions were found. The petitioner pleaded not guilty to the charges and a trial on the merits ensued. The prosecution presented evidence showing that the petitioner had possession of the firearms and ammunitions without the necessary license or permit. The defense presented a witness who claimed that the recovered pistol was allegedly pledged by a policeman to her father. The Regional Trial Court (RTC) found the petitioner guilty and sentenced him to imprisonment and a fine. The decision was affirmed by the Court of Appeals (CA). The petitioner appealed his conviction to the Supreme Court, arguing that the RTC's conclusion was based on the erroneous premise that he was the owner of the house where the firearms and ammunitions were found. The petitioner also claimed a discrepancy in the testimonies of the witnesses regarding the time the raid was conducted.

ISSUES:

  1. Whether the alleged discrepancy in the testimony of a witness regarding the time of the raid constitutes a major flaw in the prosecution's evidence.

  2. Whether ownership of the house where the unlicensed firearms and ammunition were found is an essential element of the crime charged.

  3. Whether the petitioner had control of the house where the illegal firearms were found.

  4. Whether the alleged discrepancy in the testimony of a prosecution witness regarding the time the search was conducted affects the credibility of the evidence.

RULING:

  1. The Court of Appeals (CA) held that the alleged discrepancy in the testimony of the witness regarding the time of the raid was minor and did not damage the essential integrity of the prosecution's evidence as a whole. The CA reasoned that the discrepancy was explained by the witness during her testimony. Hence, the petitioner failed to prove that the discrepancy was a major flaw in the prosecution's evidence.

  2. The ownership of the house where the unlicensed firearms and ammunition were found is not an essential element of the crime of illegal possession under PD 1866, as amended. The Supreme Court (SC) affirmed the ruling of the trial court (RTC) and the CA that ownership is not necessary, and what is required is the act of possession, which can be either actual physical possession or constructive possession. The SC further emphasized that possession includes the subjection of the thing to one's control and management. Therefore, even if the petitioner is not the owner of the house, he can still be held liable for illegal possession if he had control over the firearms and ammunition found.

  3. The Supreme Court held that petitioner did have control of the house where the illegal firearms were found. The Court considered several circumstances, including petitioner's anger and restlessness when the search warrant was served, his consent to the search being conducted, his lack of protest during the search, and his failure to call the alleged owner of the house. As such, he can be held liable for illegal possession of firearms under PD 1866 as amended.

  4. The Court found that the alleged discrepancy in the testimony of the prosecution witness regarding the time the search was conducted does not damage the essential integrity of the evidence or reflect adversely on the witness' credibility. The witness explained her mistake and there was no indication of ill-motive or perjury. Therefore, the witness' positive declarations on the witness stand deserve full faith and credence.

PRINCIPLES:

  • The findings of fact by the trial court, when affirmed by the CA, are binding on the Supreme Court, except in exceptional circumstances.

  • The essential elements of the crime of illegal possession of firearms and ammunition are the existence of the subject firearm and the lack of corresponding license or authority to possess it.

  • Ownership is not an essential element of illegal possession; what is required is the act of possession, either actual or constructive, coupled with the intent to possess.

  • Animus possidendi, or the intent to possess, can be inferred from the prior or contemporaneous acts of the accused and the surrounding circumstances.

  • The lack of authority to possess a firearm can be proven through testimonial evidence, such as the testimony of an officer from the Firearms and Explosive Division of the Philippine National Police.

  • When there is nothing to indicate that a witness was actuated by improper motives, her positive declarations on the witness stand, made under solemn oath, deserve full faith and credence.

  • Minor discrepancies in a witness' testimony do not damage the essential integrity of the evidence or reflect adversely on the witness' credibility.

  • When a special law adopts the nomenclature of the penalties in the Revised Penal Code, the latter law shall apply.