G.R. No. 261612 - Managuelod y Tandayu vs. People

On March 18, 2019, petitioner Arsenio Managuelod y Tandayu (Managuelod) was charged by Information dated May 30, 2019, with violation of Batas Pambansa Blg. 6, in relation to Republic Act No. 7166 (RA 7166), the Omnibus Election Code as amended, and COMELEC Resolution No. 10446.
The charge alleged that Managuelod willfully, unlawfully, and feloniously possessed a knife, a deadly bladed weapon, during the May 2019 election period without any valid COMELEC exemption.
The incident occurred in Tuguegarao City, Cagayan Province. Managuelod was reported to have climbed on the concrete fence and railings of Bed Spacers Hometel Inn, prompting the hotel manager to seek police assistance.
Police officers apprehended Managuelod, searched his sling bag, and recovered a knife with camouflage holster.

The prosecution presented Police Officer I Patrocinio Lappay (PO1 Lappay) and Police Staff Sergeant Edwin Pagulayan (PSSg Pagulayan) as witnesses.
The defense presented Managuelod as its sole witness.

Hotel manager Giero D. Tumabao saw Managuelod climbing the fence and railings late at night, which led to the police being called.
SPO2 Edmar Allam and PO1 Lappay arrived, arrested Managuelod, and upon arrest saw a knife handle protruding from his sling bag.
The knife was confiscated, marked with PO1 Lappay's initials, and brought to the police station along with Managuelod and the hotel manager.
Photographs were taken, and the seized items were presented in court.

Managuelod claimed that while driving and stopping to urinate, two men on a motorcycle approached him.
One drew a firearm, handcuffed him, and brought him to the police station without lawful authority.
He denied possession of any deadly weapon or unlawful conduct.

The Regional Trial Court (RTC) found Managuelod guilty beyond reasonable doubt.
He was sentenced to imprisonment of 1 year and 4 months to 3 years and 8 months and disqualified from holding public office and suffrage.

The Court of Appeals affirmed the RTC decision, holding that Managuelod carried a deadly weapon in a public place during the election period without authorization.
It rejected claims that the location was private or that carrying the weapon was necessary for his profession.

Managuelod filed a Petition for Review on Certiorari before the Supreme Court contesting the findings.
He questioned the credibility of prosecution witnesses, lack of corroboration, absence of marking on the knife, and argued the location was private.

Whether the prosecution proved beyond reasonable doubt that Managuelod illegally possessed a deadly weapon during the election period in a public place.
Whether the physical evidence, specifically the knife alleged to be confiscated, was properly identified and admissible.
Whether the place where Managuelod was apprehended constituted a "public place" under the law.
Whether the prosecution witnesses' testimonies and procedures followed were credible and consistent.
Whether the petitioner’s possession of the deadly weapon was necessary for his profession or lawful activity.