G.R. No. 182694 - Madrigal vs. People

Petitioner Igmidio Madrigal was charged with two separate offenses related to the possession of an unlicensed firearm during the 1998 election period in San Pedro, Laguna.
The charges were filed under two distinct Criminal Cases:

Criminal Case No. 1026-SPL for illegal possession of a firearm (violation of PD 1866, as amended by RA 8294).
Criminal Case No. 1025-SPL for violation of the Omnibus Election Code (commonly known as the Gun Ban, as amended by RA 7166).

On or about March 31, 1998, within the election period (January 11 to June 10, 1998), Madrigal was alleged to have unlawfully possessed a caliber .38 Smith & Wesson revolver.
In Criminal Case No. 1026-SPL, the firearm was described as lacking a serial number and containing live ammunition along with a split shell.
In Criminal Case No. 1025-SPL, the allegation focused on the possession of the unlicensed firearm without the necessary permit from the COMELEC while outside his residence.

At arraignment, petitioner pleaded not guilty to both charges.
The Regional Trial Court (RTC) of San Pedro, Laguna, Branch 93, after trial on the merits, found Madrigal guilty beyond reasonable doubt on both offenses.
RTC Sentencing:

In Criminal Case No. 1026-SPL, he was sentenced to an indeterminate penalty of imprisonment ranging from a minimum of two years, eleven months, and ten days to a maximum of five years, four months, and twenty days in prision correccional, and ordered to pay a fine of ₱15,000.00.
In Criminal Case No. 1025-SPL, he was sentenced to an indeterminate penalty of imprisonment, with a minimum of one year and a maximum of three years, including accessory penalties provided by law.

Madrigal appealed the RTC decision.
The Court of Appeals (CA) affirmed his conviction in both offenses but reduced the penalty imposed in Criminal Case No. 1026-SPL for illegal possession of the firearm.

Madrigal questioned the factual findings established by the lower courts regarding his possession of the unlicensed firearm during the election period.
More critically, he contested his conviction on both offenses on the ground that RA 8294 prohibits a conviction for illegal possession of firearms when another crime is also committed concurrently.
The petitioner sought his acquittal for the illegal possession charge while maintaining the dispute regarding the dual conviction.

Whether the lower courts properly found that Madrigal was in possession of an unlicensed firearm containing live ammunition during the election period.

Whether Madrigal’s conviction for illegal possession of a firearm under RA 8294 is valid when another offense, namely the violation of the election gun ban, was committed concurrently.
How Section 1 of RA 8294, with its proviso "Provided, That no other crime was committed," impacts the dual conviction in cases where overlapping criminal conduct is present.
Whether the precedent set in Agote v. Lorenzo, which addresses the same issue of overlapping crimes, should control the present case.