G.R. No. 240475 - De Guzman y Aguilar vs. People

Jonathan De Guzman y Aguilar (De Guzman), petitioner, was charged with illegal possession of a firearm for allegedly possessing one (1) Smith and Wesson Caliber .38 Revolver loaded with four (4) live ammunition without the necessary license or authority, contrary to Republic Act No. 10591 (Comprehensive Firearms and Ammunition Regulation Act).
The case arose from an incident on or about October 22, 2014, in Pasay City, Philippines.

At around 4:00 p.m. on October 22, 2014, Senior Police Officer 1 (SPO1) Ador Estera and nine (9) other police officers patrolling Taft Avenue, Libertad, Pasay City, witnessed people running away from the White House Market.
SPO1 Estera saw De Guzman wielding a revolver and shouting as if quarreling.
The officers identified themselves as police, commanded De Guzman to put down the gun, which he complied with.
Upon frisking, SPO1 Estera found the revolver and four live ammunitions, which he marked with petitioner’s initials.
A sachet of suspected shabu was also allegedly found during frisking.
De Guzman was taken to Pasay City Police Station and referred to SPO3 Allan Valdez, to whom the seized items were turned over.

De Guzman alleged he was arrested on October 21, 2014—not October 22, 2014—as he and his sister Jessica were dressing chicken for sale at a public market.
SPO1 Estera, among 10 men in civilian attire, approached De Guzman, questioned him about his knives used for dressing poultry, and asked about a mayor's permit.
Upon De Guzman's allegedly rude reply, SPO1 Estera pointed a gun at him, took his knives, forced him to lie on his stomach, frisked him (finding nothing), and announced his arrest for possession of knives.
At the police station, SPO1 Estera reportedly demanded P300,000.00 to avoid charging De Guzman with illegal possession of firearms and drugs.
De Guzman denied knowledge of SPO1 Estera before the incident but noted that about a month earlier, he had won a P50,000 cockfight bet against him, which allegedly sparked a vendetta.
De Guzman admitted owning a licensed .45 caliber Amscor firearm but denied possessing the unlicensed .38 caliber revolver.

De Guzman pleaded not guilty; trial ensued.
The prosecution presented only SPO1 Estera as witness.
The Regional Trial Court (RTC), Branch 114, Pasay City, convicted De Guzman on March 1, 2017, finding the prosecution proved the firearm and ammunition were recovered from him and that he admitted lack of license for the .38 caliber revolver.
De Guzman separately faced a related charge for illegal possession of dangerous drugs before RTC Branch 110 and was acquitted on April 3, 2018, because the arrest was deemed unlawful and evidence inadmissible.

CA affirmed with modification the RTC’s conviction in its March 21, 2018 Decision.
CA denied De Guzman’s Motion for Reconsideration in its July 5, 2018 Resolution.

De Guzman filed a Petition for Review on Certiorari praying for reversal of the CA Decision and his acquittal.
The Supreme Court reviewed the sufficiency of evidence, the credibility of the lone police witness, multiple inconsistencies, and alleged vendetta motives.

Whether the prosecution proved beyond reasonable doubt that De Guzman was guilty of illegal possession of a firearm under Republic Act No. 10591.

Whether the lone testimony of the police officer was credible and sufficient to establish the elements of the offense.