Facts:

In the case of Cayetano Capangpangan vs. People of the Philippines (G.R. No. 150251, November 23, 2007), the petitioner, Cayetano Capangpangan, was charged with illegal possession of firearms, ammunitions, and explosives under Presidential Decree No. 1866. The events unfolded on July 1, 1997, in Tagoloan, Lanao del Norte, where agents from the National Bureau of Investigation (NBI), accompanied by soldiers from the 30th Infantry Brigade and barangay officials, conducted a search of Capangpangan's residence. They had a valid search warrant for his house but found a cache of illegal firearms hidden in an abandoned hut nearby. Among the recovered items were five hand grenades, various types of ammunitions, and several firearms, all confiscated without proper licenses.

During the trial, Capangpangan pleaded not guilty and challenged the legality of the search, arguing that the items were not discovered in his house but rather in an uninhabited hut. Witnesses for the defense cor

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Facts:

Background of the Case

• Petitioner, Cayetano aTanoa Capangpangan, was charged with illegal possession of firearms, ammunitions, and explosives under Presidential Decree No. 1866, as amended.
• The case was docketed as Criminal Case No. 03-6752 in the Iligan City Regional Trial Court (RTC).
• On or about July 1, 1997, at Tagoloan, Lanao del Norte (and areas in Lanao del Sur), various contraband items were allegedly found including:
• Five (5) live handgrenades
• Eight (8) garand clips and sixteen (16) additional garand clips without ammunition
• Twenty-two (22) pieces of .45 caliber ammunition
• Forty (40) pieces of M16 Armalite ammunition
• Five (5) pieces of carbine ammunition
• Three (3) pieces of M16 magazines (empty)
• One (1) garand trigger housing group
• One (1) shotgun rifle with serial number SN-126184
• Two (2) .22 caliber rifles with specific serial numbers
• One (1) defaced shotgun
• One (1) defaced single-shot M16 home-made .22 caliber rifle
• One (1) S&W .22 magnum without the necessary license or permit.

Search and Seizure Details

• The search was conducted based on a valid warrant.
• National Bureau of Investigation (NBI) agents, in cooperation with soldiers from the 30th Infantry Brigade and barangay officials, conducted the search at petitioner’s house in Patag, Tagoloan.
• During the search:
• A section of the ceiling was opened revealing an ammunition box containing various arms and ammunition.
• An inventory was made on the spot, with the document signed by NBI agent Nolan Gadia and barangay kagawads Esterlita Laurente and Renato Abellar.
• The inventory was executed in the presence of petitioner and his wife, Eldrid Nacua.

Evidence Presented by the Parties

• Evidence for the Prosecution:
• The seizure and inventory of arms were supported by the testimony of multiple officials, including NBI agents and members of the 30th Infantry Brigade.
• Petitioner’s admission that he did not possess the required firearms license was recorded during the proceedings.
• A certification issued by SPO1 Delfin E. Regis of the Philippine National Police (PNP) in Iligan City was introduced, stating that there was no record of a license for petitioner in the computerized firearms license registry.
• Evidence for the Defense:
• Petitioner argued that the search was illegal because the items were discovered in an abandoned hut, not in his house as specified in the warrant.
• Testimonies by Sgt. Roberto Legaspi and Cpl. Romeo Sagarino depicted that the contraband was found in a hut where petitioner and several others were seen surveying land.
• Petitioner testified that at the time of the incident, he was on his land at Sitio Paliamon, Tagoloan, not at the location where the cache was allegedly discovered.
• Witnesses such as Rolando Guevara, Rodolfo Fernandez, and others provided accounts that corroborated petitioner’s version regarding the location and circumstances of the discovery, although these were inconsistent in some respects.

Proceedings in the Lower Courts

• Regional Trial Court Decision:
• On August 5, 1999, the RTC found petitioner guilty beyond reasonable doubt and sentenced him to an indeterminate penalty ranging from four years, two months and one day to eight years imprisonment.
• The court ordered the cancellation of the bail bond and the immediate incarceration of the petitioner, as well as the confiscation of the seized firearms.
• The RTC credited the prosecution’s witnesses and found the defense’s version—regarding the alleged location of the contraband and other inconsistencies—to be highly unusual and implausible.
• Court of Appeals Decision:
• The CA reviewed the sole issue of the credibility of the witnesses.
• It affirmed the trial court’s findings “in toto,” relying on the trial court’s assessment of the witnesses’ credibility and the prima facie evidence of the petitioner’s lack of a valid firearms license.
• The CA dismissed the petitioner’s motion for reconsideration, reiterating that the trial court’s findings were binding unless there was clear evidence of an error.

Issue:

• Whether the Court of Appeals erred in convicting petitioner absent adequate proof to establish his lack of a firearms license.
• Whether the CA improperly gave full credence to the testimonies of the prosecution’s NBI witnesses, disregarding the defense’s evidence and rebuttal witness testimonies (including those of two members of the army).
• Whether the trial court erred in not crediting the defense’s contention that the firearms and related items were not seized from petitioner’s house but from an abandoned location (i.e., elsewhere).
• Whether the trial court’s finding of petitioner’s guilt beyond reasonable doubt for the violation of PD 1866, as amended, was erroneous.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)