G.R. No. 248907 , April 26, 2021
Ruben De Guzman y Lazano, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Ruben De Guzman y Lazano was charged with illegal possession of a firearm under PD 1866, as amended by R.A. 8294. The Information alleged that on December 25, 2010, in Enrile, Cagayan, he willfully and unlawfully possessed an unlicensed M16 Baby Armalite with magazine and 17 rounds of live ammunition, which he carried outside his residence without the necessary license or permit. During pre-trial, the parties admitted several facts, including the accused’s presence in Enrile on the date, the surrender of the subject firearm by Dionisio Jarquio and Ramil Pajar to the police, and that the firearm was not licensed. The prosecution’s version, based on the testimonies of Dionisio Jarquio and Ramil Pajar, was that Dionisio confronted Ruben after being told Ruben threatened his son; during the confrontation, Dionisio saw a baby armalite hanging on Ruben’s body, grappled with him for it, and Ramil eventually took the firearm from Ruben, who then fled. The firearm was surrendered to the police. The defense’s version, based on Ruben’s testimony and that of Silverio Severo and Felisa Zingapan, was that Ruben, a barangay tanod, was on patrol when Dionisio, holding a grudge due to political rivalry, poked a .45 caliber gun at him, and then George and Roman Jarquio mauled him, striking him with a long firearm, causing a head injury. Ruben was brought to the hospital and later went to the police station to report the mauling, where he was instead arrested. The Regional Trial Court (RTC) convicted Ruben, sentencing him to 6 years and 1 day to 8 years imprisonment and a fine. The Court of Appeals (CA) affirmed the conviction but modified the penalty. Ruben filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming petitioner Ruben De Guzman’s conviction for illegal possession of firearm, based on the evidence presented.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the CA Decision and Resolution, and ACQUITTED Ruben De Guzman y Lazano. The Court held that the prosecution failed to prove his guilt beyond reasonable doubt. The elements of illegal possession of firearm are: (1) the existence of the firearm; and (2) the fact that the accused who owned or possessed it does not have the corresponding license or permit. While the firearm’s existence and lack of license were established, the prosecution failed to prove the crucial element of possession (animus possidendi) by the accused. The testimonies of the prosecution witnesses, Dionisio Jarquio and Ramil Pajar, were inconsistent and unreliable. Dionisio gave conflicting statements about how the firearm was taken from Ruben (initially stating he alone wrestled it away, then later that Ramil took it). Ramil’s testimony that he pulled the firearm upward because it had a sling contradicted Dionisio’s claim of a struggle and was improbable if Ruben was actively grappling for it. The defense evidence, including the testimony of disinterested witnesses Silverio Severo and Felisa Zingapan and the Medico-Legal Certificate confirming Ruben’s injury from a mauling, cast reasonable doubt on the prosecution’s narrative. The police merely relied on the report of Dionisio and Ramil without independent verification. Therefore, the evidence did not overcome the constitutional presumption of innocence.