Case Digest (G.R. No. 248529) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Mark Alvin Lacson y Marquesses a.k.a. “Mac-Mac,” Noel Agpalo y Sacay, and Moises Dagdag y Corpuz (G.R. No. 248529, April 19, 2023), the respondents were charged in five separate informations before the Regional Trial Court (RTC) of Pasig for illegal possession of explosives and firearms under Presidential Decree No. 1866 as amended by Republic Act No. 9516, illegal possession of a firearm and ammunition under Sections 28(a) and 28(e)(1) of Republic Act No. 10591, and violation of Comelec Resolution No. 9735 (election gun ban) in connection with the October 28, 2013 Barangay Elections. On October 7, 2013, members of the Taguig Police Station’s Tactical Motorcycle Riders Unit, while conducting “Oplan Sita” along C-5 Road, allegedly spotted Lacson, Agpalo, and Dagdag acting “suspicious” and attempting to flee. Upon interception, Police Officer II Rommel Paparon frisked Agpalo and recovered a loaded Paltik revolver with ammunition; Police Officer I L Case Digest (G.R. No. 248529) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Plaintiff-Appellee: People of the Philippines; Accused-Appellants: Mark Alvin Lacson y Marquesses and Noel Agpalo y Sacay; Co-accused: Moises Dagdag y Corpuz.
- Five separate Informations (Crim. Case Nos. 152327–152331-TG) charged them with:
- Illegal possession of a hand grenade (P.D. No. 1866 as amended).
- Illegal possession of a hand grenade during the election period (Comelec Resolution No. 9735).
- Illegal possession of a “paltik” revolver and live ammunition (RA 10591).
- Possession of the same firearms/ammunition during the election period (Comelec Resolution No. 9735).
- Illegal carrying of a bladed weapon during the election period (Comelec Resolution No. 9735).
- Arrest, Evidence and Trial
- On October 7, 2013, members of the Taguig Police’s Tactical Motorcycle Riders Unit, under “Oplan Sita,” received a report on a snatching along C-5 Road, saw Lacson, Agpalo, and Dagdag loitering, and approached them. The three fled but were intercepted.
- Frisking recovered from Agpalo a loaded “paltik” revolver with four live rounds; from Lacson a hand grenade. Dagdag was separately apprehended; a bladed weapon was allegedly seized from him.
- Defendants denied ownership, claimed frame-up and brutality. At the precinct, police allegedly used Agpalo’s phone to lure him in and then arrested him.
- RTC (Sept. 5, 2017) convicted Lacson and Agpalo of the charged offenses, acquitted Dagdag for lack of proof, and ordered forfeiture of seized items.
- CA (Jan. 17, 2019) affirmed RTC, ruling appellants had waived any arrest/search irregularity by not quashing the Informations before arraignment.
Issues:
- Whether the warrantless arrests of Lacson and Agpalo were valid.
- Whether the warrantless searches (stop-and-frisk) yielding the grenade, firearm, and ammunition were valid.
- Whether the guilt of Lacson and Agpalo was proven beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)