G.R. No. 119255 - Chua vs. Court of Appeals

Section 26 of Act No. 1780 prohibits carrying concealed weapons, specifically naming items such as bowie knives, dirks, daggers, kris, and "other deadly weapon[s]."
The term “deadly weapon” is defined as any instrument which, from the use made of it at the time, is likely to produce death or cause great bodily harm. This definition is supported by judicial citations, including references to demons vs. State and Bish. New Cr. Law.
Some statutes explicitly list “brass knuckles” as a prohibited weapon, while others utilize the phrase “or other deadly weapon” to cover similar implements.

During a raid at a certain club, police officers discovered a pair of brass knuckles (locally referred to as "llave inglesa") concealed in the pocket of the accused.
Brass knuckles are defined as a weapon designed to be worn on the hand for offensive or defensive purposes, built in such a way that a blow with the fist results in considerable damage. Although originally made of brass, the term now applies regardless of the material used.

The central question before the Court was whether brass knuckles fall within the definition of a “deadly weapon” as contemplated by Section 26 of Act No. 1780.
An examination of the physical characteristics and potential for causing bodily injury led the Court to assess the inherent dangers of the weapon.

Prior jurisprudence, such as U. S. vs. Santo Nino and State vs. Hall, served as corroborative authority in affirming the inclusion of weapons of different classes under the statute’s ambit.
Counsel for the appellant raised the argument that intent is an essential element, contending that mere possession without harmful intent or knowledge does not constitute an offense.
However, emphasis was placed on the fact that carrying brass knuckles, given their potential for inflicting serious harm, could not be justified as a harmless act or as an inadvertent possession.

Does the statutory definition of “deadly weapon” encompass brass knuckles, considering their design and potential to inflict great bodily harm?
Can a weapon that is not explicitly named in the statute be included under the broad phrase “or other deadly weapon”?

Is the requisite intent for committing the offense one that is inherently presumptive upon possession, or must the prosecution prove that the accused carried the weapon with the purpose of engaging in combat?
How does the burden of proof shift between the state and the defendant regarding the concealment and intent of carrying the weapon?

Did the defendant have any statutory exception, such as carrying the weapon innocuously (e.g., for transport from a purchase or repair), that might have justified the presence of the brass knuckles?
Was the concealment of the weapon properly established by the state, thereby overcoming any presumptions favoring the defendant?