G.R. No. L-6084 - People vs. Catchero

This case involves an appeal by the People of the Philippines against the defendant, Ricardo Catchero, following the dismissal by the Court of First Instance of Pangasinan.
The dismissal was based on a motion to quash an information charging the defendant with illegal possession of a firearm and ammunition.

The information alleged that the defendant had possession, custody, and control of the firearm and ammunition without the required license.
It did not allege that the defendant made use of the firearm and ammunition except in self-defense nor that he carried them on his person for the purpose of surrendering them to the authorities.

The lower court held that the information failed to state facts sufficient to constitute an offense under the applicable law.
The court relied on precedents such as People vs. Santos Lopez y Jacinto and People vs. Ricardo Aquino y Abalos, which held that mere possession did not attract criminal liability unless the accused used the firearm except in self-defense or carried it for surrender.
The cases cited applied to offenses committed before the expiration of the period fixed in Proclamation No. 1 (July 20, 1946) for the surrender of unlicensed firearms and ammunition.

The rulings in Santos Lopez were relevant only for acts committed before the imposed deadline of August 31, 1946, during which mere possession was not punishable.
After August 31, 1946, when the suspension of penalties for mere possession terminated, the general rule rendering the possession, manufacture, sale, etc. of firearms and ammunition unlawful was reimposed.

The violation charged was alleged to have been committed on or about August 16, 1949.
Since this date is after the deadline for surrender under Proclamation No. 1 and after the termination of the suspension, the facts placed the defendant within the ambit of the reimposed criminal liability.

Does the information state facts sufficient to constitute an offense of illegal possession of firearm and ammunition under the law?
Is the allegation of mere possession, without additional qualifying circumstances (e.g., use except in self-defense or carrying for surrender), adequate to establish criminal liability?

Is the rule in People vs. Santos Lopez y Jacinto, which provided immunity for mere possession before August 31, 1946, applicable to the current case involving possession in 1949?
Should the temporal distinction between possession before and after the termination of the suspension period dictate the sufficiency of the charge?

Does the defendant have any valid defense or exculpatory evidence that might justify his possession of the firearm and ammunition despite the time factor?
How does the absence of allegations regarding the use of the firearm, except in self-defense, affect the interpretation of the offense committed after the suspension period?