G.R. No. 157643 - Fermin vs. People

Twenty-six (26) Petitions for Review filed by the People of the Philippines, represented by the City Fiscal of Manila, the Provincial Fiscal of Samar, and joined by the Solicitor General.
Three Courts of First Instance (CFI) involved:

CFI of Manila, Branch VII (Judge Amante P. Purisima) – 17 petitions (G.R. L-42050-66).
CFI of Manila, Branch XVIII (Judge Maximo A. Maceren) – 8 petitions (G.R. L-46229-32; L-46313-16).
CFI of Samar (Judge Wenceslao M. Polo) – 1 petition (G.R. L-46997).

Common allegations: accused “willfully, unlawfully and knowingly” carried outside residence a bladed or pointed weapon (e.g., carving knife, ice pick, “socyatan”), not used as a necessary tool to earn a livelihood.
Caption and body of each Information cited “Violation of paragraph 3, Presidential Decree No. 9 (PD 9) of Proclamation 1081,” with variations only in accused’s name, date, place, and weapon.

Accused moved to quash on ground that Informations failed to allege the essential element of connection with subversion, insurrection, organized lawlessness or public disorder.
Judge Purisima (Manila, Branch VII) quashed for lack of allegation that possession was “for the purpose of abetting or in furtherance” of conditions justifying PD 9 enforcement.
Judge Maceren (Manila, Branch XVIII) quashed, holding that PD 9 §3 penalizes only weapons carried in furtherance of insurrection, rebellion, or lawless violence; mere carrying outside residence is not unlawful.
Judge Polo (Samar) quashed, reasoning that PD 9 §3 targets possession of deadly weapons connected with subversion, rebellion or public disorder, not ordinary self-defense or farm use.

Whether the Informations filed under PD No. 9, §3, sufficiently allege all essential elements of the offense.
What are the elements of illegal possession of a deadly weapon under PD No. 9, §3, and must they be expressly alleged?
Whether trial courts properly dismissed or quashed the Informations for failure to state a punishable offense.