Case Digest (G.R. No. L-18766) Core Legal Reasoning
Core Legal Reasoning
Facts:
On December 21, 1960, at around 10:00 A.M., the Chief of Police of Bacuag, Surigao del Norte apprehended three suspicious individuals—Ramon Lopez, Manuel Buico, and Arturo Caniete—who were loitering in Pagao, a sitio of Bacuag. During the apprehension, the police confiscated a bag they were carrying, which contained three caliber .30 M1 carbines, a caliber .22 revolver, fully loaded ammunition magazines, carbine ammunition, several flashlights, a balisong, a screwdriver, and seven false keys, one of those being a master key. These three individuals were subsequently charged in the Justice of the Peace Court of Bacuag with illegal possession of firearms and, separately, with illegal possession of false keys. While Buico and Caniete pleaded guilty to the charge related to the firearms, Lopez pleaded not guilty concerning the charge of illegal possession of false keys. The charges were later elevated to the Court of First Instance of Surigao del Norte, where the Assistant Provincia Case Digest (G.R. No. L-18766) Expanded Legal Reasoning
Expanded Legal Reasoning
Facts:
- Arrest and seizure
- On December 21, 1960 at 10:00 A.M., the Chief of Police of Bacuag, Surigao del Norte apprehended three suspicious strangers loitering in Pagao, a sitio of Bacuag.
- A bag carried by the three was seized; its contents included three carbines (.30 M1), one revolver (.22), three flashlights with batteries, two fully loaded carbine magazines, twelve rounds of carbine ammunition, one balisong, a screw driver, seven false keys (one described as a master key or picklock), trousers, shirts, and a pair of shoes.
- Preliminary proceedings and charges
- The three occupants of the bag were identified as Ramon Lopez, Manuel Buico, and Arturo Caniete. They were charged in the Justice of the Peace Court of Bacuag with illegal possession of firearms and, in a separate complaint, illegal possession of false keys.
- All three pleaded guilty to illegal possession of firearms and were convicted on December 24, 1960 by the Justice of the Peace Court (Criminal Case No. 374), each sentenced to three years imprisonment and fined P2,000.00.
- The record on the false keys complaint was transmitted to the Court of First Instance of Surigao del Norte, and an information was filed against the three, alleging illegal possession of seven false keys, one of which was a picklock or master key, and charging that possession was "without lawful cause." The information also alleged the aggravating circumstance that the accused had been previously punished for an offense with an equal or greater penalty (the firearms conviction).
- Pleas, trial events and dismissal
- Of the three accused, Buico and Caniete pleaded guilty to the false keys charge; Lopez pleaded not guilty and stood trial.
- After the prosecution presented one witness, Lopez moved to dismiss the information on the ground that the facts charged did not constitute an offense. The defense argued that an essential element of Article 304 (possession of picklocks or similar tools specially adapted to commission of robbery) was not alleged in the information — namely, that the picklock or false keys were "specially adapted to the commission of the crime of robbery."
- The trial court sustained the motion and dismissed (quashed) the information for insufficiency. The prosecution appealed to the Supreme Court.
Issues:
- Sufficiency of the information
- Whether the information as framed (alleging possession of seven false keys, one of which is a picklock or master key, "without lawful cause") sufficiently alleges all essential elements of the offense under Article 304 of the Revised Penal Code.
- Statutory interpretation and necessary allegations
- Whether it is necessary, for the sufficiency of an information, to state expressly that the picklocks or similar tools in the accused's possession were "specially adapted to the commission of the crime of robbery," or whether the allegation of possession of a picklock/false keys suffices.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)