Case Digest (G.R. No. 245334)
Facts:
- The case involves Mark Ramsey Javier y Titular (petitioner) against the People of the Philippines (respondent).
- The events occurred on June 1, 2016, in Muntinlupa City during the election period from January 10, 2016, to June 8, 2016.
- An Information dated June 2, 2016, charged the petitioner with violating Section 261(p) of Batas Pambansa Bilang 881 (Omnibus Election Code) for unlawfully possessing a bladed weapon (a folding knife measuring approximately eight inches) without authorization from the Commission on Elections (COMELEC).
- At around 5:50 a.m., police officers conducting "Oplan Sita" noticed the petitioner riding a motorcycle without a helmet.
- The petitioner initially ignored the officers' attempts to flag him down, leading to a chase.
- Upon stopping him, the police requested his driver's license and registration, which he could not provide, claiming the motorcycle was newly purchased.
- The officers handcuffed him and found the folding knife in the motorcycle's compartment, marking it with the initials "MRTJ" for safekeeping.
- The prosecution presented a COMELEC Certification indicating the petitioner had not applied for authorization to carry deadly weapons during the election period.
- The petitioner denied ownership of the knife, claiming he only saw it for the first time at the police station.
- The Regional Trial Court (RTC) found the petitioner guilty on March 22, 2017, sentencing him to three to six years of imprisonment, disqualification from holding public office, and deprivation of the right to suffrage.
- The Court of Appeals (CA) affirmed the RTC ruling on August 31, 2018, and denied a motion for reconsideration on February 14, 2019.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, reversing the decisions of the RTC and CA, and acquitted the petitioner due to the prosecution...(Unlock)
Ratio:
- The Supreme Court emphasized the presumption of innocence in criminal cases and the prosecution's burden of proof.
- The Court noted that the RTC and CA overlooked critical facts regarding the chain of custody of the folding knife.
- The prosecution failed to establish that the knife presented in court was the same one allegedly confiscated from the petitioner.
- The importance of adhering to chain of custody rules, as outlined in the Philippine National Police (PNP) Criminal Investigation Manual, was highlighted.
- The police officer...continue reading
Case Digest (G.R. No. 245334)
Facts:
The case involves Mark Ramsey Javier y Titular (petitioner) against the People of the Philippines (respondent). The events leading to the case unfolded on June 1, 2016, in Muntinlupa City, Philippines, during the election period from January 10, 2016, to June 8, 2016. An Information dated June 2, 2016, charged the petitioner with violating Section 261(p) of Batas Pambansa Bilang 881, also known as the Omnibus Election Code, for unlawfully possessing a bladed weapon—a folding knife measuring approximately eight inches—without the necessary authorization from the Commission on Elections (COMELEC).
On the day of the incident, around 5:50 a.m., police officers conducting "Oplan Sita" noticed the petitioner riding a motorcycle without a helmet. When they attempted to flag him down, he initially ignored them, leading to a chase. Upon stopping him, the police officers requested his driver's license and registration, which he could not provide, claiming the motorcycle was newly purchased. The officers subsequently handcuffed him and discovered the folding knife in the motorcycle's compartment.
The police marked the knife with the initials "MRTJ" and later turned it over to a senior officer for safekeeping. During the trial, the prosecution presented a COMELEC Certification indicating that the petitioner had not applied for or received authorization to carry deadly weapons during the election period. The petitioner, however, contended that he did not evade the checkpoint and denied ownership of the knife,...