Title
Javier y Titular vs. People
Case
G.R. No. 245334
Decision Date
Feb 8, 2023
A motorcyclist was acquitted after the Supreme Court ruled the prosecution failed to establish an unbroken chain of custody for a folding knife allegedly found during his arrest, creating reasonable doubt.

Case Digest (G.R. No. L-15939)
Expanded Legal Reasoning Model

Facts:

  • Antecedents
    • Information filed (June 2, 2016): Petitioner charged under Section 261(p), BP 881 (Omnibus Election Code), as amended by Section 32, RA 7166, for possessing a folding knife during the election period without COMELEC authorization.
    • Arrest (June 1, 2016): Police conducting “Oplan Sita” in Muntinlupa City stopped petitioner for riding a motorcycle without helmet, license, or plate. After a chase, he was handcuffed; a folding knife (approx. 8 inches) was allegedly recovered from the motorcycle compartment.
  • Trial Proceedings
    • Prosecution evidence:
      • Police testimony regarding the traffic stop, arrest, marking of the knife “MRTJ,” confiscation, photographing, and turnover to evidence custodian.
      • COMELEC Certification (July 5, 2016) confirming petitioner had no written permit to carry deadly weapons during the election period.
    • Defense evidence:
      • Petitioner’s account: He stopped when signaled, lost helmet and license, newly purchased motorcycle without plates; first saw the knife at the police station.
      • Denial of intent to evade and of owning the knife at the scene.
  • Lower Court Rulings
    • RTC Decision (March 22, 2017): Found petitioner guilty beyond reasonable doubt; sentenced to 3–6 years imprisonment, disqualification, deprivation of suffrage; ordered forfeiture of knife.
    • CA Decision (August 31, 2018) and Resolution (February 14, 2019): Affirmed RTC, ruling arrest lawful (no warrant needed), knife admissible, and petitioner not exempt from election-period ban on weapons.

Issues:

  • Whether petitioner was proven guilty beyond reasonable doubt of violating Section 261(p), BP 881, for bearing a deadly weapon during the election period without COMELEC authorization.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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