Facts:

• The case involves the People of the Philippines as the plaintiff-appellee against Enrique Sollano, Jr. and several co-defendants.
• Co-defendants include Nepomuceno Laude, Romulo Tumulak, Rodulfo Tumulak, Piniong Laude (alias Eufemio Tito), and Ating Laum, Jr.
• Decided on October 29, 1971, by the Supreme Court of the Philippines under G.R. No. L-29570.
• Originated from the Court of First Instance of Cebu, where Sollano was convicted of illegal possession of firearms in Criminal Case No. V-8955.
• The amended information charged the defendants with illegal manufacture of firearms, alleging conspiracy to manufacture without permits on March 30, 1962, in Danao City.
• The prosecution's case relied on undercover agent Nicanor Baring, who purchased three revolvers from Sollano on March 15, 1962.
• A raid on March 30, 1962, led to the confiscation of firearms and manufacturing paraphernalia.
• Sollano was convicted for illegal possession, while his co-accused were acquitted due to reasonable doubt.

Issue:

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Ruling:

• The Supreme Court affirmed the lower court's judgment, convicting Enrique Sollano, Jr. of illegal possession of firearms.
• The Court ruled that illegal possession does not necessarily include illegal manufacture, but the latter inherently includes the former.
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Ratio:

• The Court's reasoning focused on the relationship between illegal possession and illegal manufacture of firearms.
• It established that while illegal possession is not a necessary component of illegal manufacture, manufa...continue reading