Case Digest (G.R. No. 163267) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Teofilo Evangelista vs. The People of the Philippines, petitioner Teofilo Evangelista, a Filipino national arriving on Philippine Airlines Flight No. 657 from Dubai on January 30, 1996, was met at Ninoy Aquino International Airport (NAIA), Pasay City, by Customs Police Officer Maximo Acierto Jr. and other agents. During inspection, Evangelista admitted to owning one 9mm Jericho pistol (SN F-36283) with one magazine, one Mini-Uzi 9mm submachine gun (SN 931864) with two magazines, and nineteen 9mm bullets, none of which were covered by a permit from the Firearms and Explosive Office (FEO). He executed a Customs Declaration Form indicating that the firearms were “sent surrender to Philippine Airlines.” Following his arrest and posting of bail, Evangelista successfully moved for a preliminary investigation, which resulted in a State Prosecutor finding no probable cause to indict. The prosecutor’s subsequent Motion to Withdraw Information was denied by the Regional Trial Court (RT Case Digest (G.R. No. 163267) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- On January 31, 1996, petitioner Teofilo Evangelista was charged in the RTC of Pasay City with violation of Section 1, PD No. 1866, as amended, for alleged possession of a 9 mm Jericho pistol, a 9 mm Mini-Uzi submachine gun with magazines, and 19 rounds of ammunition without a license.
- Petitioner posted bail, moved to suspend proceedings for preliminary investigation, and the State Prosecutor found no probable cause on March 6, 1996. The trial court denied the Motion to Withdraw Information and proceeded to arraignment.
- Factual Narrative
- Prosecution Version: Customs Police SPO1 Maximo Acierto Jr. was alerted that a passenger arriving on PAL Flight No. 657 from Dubai would bring firearms. At NAIA, petitioner admitted to possessing firearms bought in Angola, which pilot Capt. Edwin Nadurata accepted custody of in Dubai and turned over to authorities in Manila. Petitioner’s lack of license was confirmed by FEO certification. He was unrepresented during admission.
- Defense Version: Petitioner claimed Arab police in Dubai forced him to accept ownership under threat of imprisonment. PAL Station Manager Nilo Umayaw intervened, arranging that Capt. Nadurata carry the firearms and petitioner to Manila. They stipulated that the firearms were confiscated in Dubai and handed to Nadurata for petitioner’s release.
Issues:
- Whether petitioner was in possession—actual or constructive—of firearms and ammunition within Philippine jurisdiction.
- Whether the crime constituted a continuing offense subject to Philippine jurisdiction.
- Whether the trial court erred in disregarding the State Prosecutor’s finding of no probable cause.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)