G.R. No. 192048 - Anama vs. Citibank, N.A.

On July 9, 1908, while walking through a street in the town of Santa Rosa, Province of Nueva Ecija, Ricardo Samson was seen carrying a shotgun and nine cartridges.
Municipal policemen apprehended Samson and seized both the firearm and the ammunition.

It was established that the shotgun belonged to Pablo Padilla, who was the lawful owner of the arm.
Pablo Padilla possessed a proper permit authorizing the possession of the firearm.
Samson was carrying the firearm on behalf of Pablo Padilla, having been instructed to do so.
The arrangement was such that while Samson was on foot with the firearm, Pablo Padilla was to follow on horseback as they proceeded for a hunting trip.

During the inquiry, the fiscal interrogated Samson regarding the ownership and the permit related to the weapon.
Samson acknowledged that he carried the shotgun and affirmed that it belonged to him at the time he was asked about it.
Upon further questioning, it was clarified that the possession was by arrangement with Pablo Padilla and that the permit in question was issued in his name as evidence of lawful authorization.
The exchange during the hearing corroborated the fact that the custody was executed under explicit instructions.

The Court of First Instance of Nueva Ecija sentenced Samson to pay a fine of P50, with a provision for subsidiary imprisonment should he fail to pay, measured at one day’s imprisonment for every P2.50 of the fine.
Additionally, Samson was burdened with the costs of the proceedings.

The issue was focused on whether the act of carrying the firearm, while not being the owner but doing so under the owner's directive, constituted illegal possession.
It was indicated that the possession did not have the intent of demonstrating unlawful ownership or usage but was an act executed per instructions.

Whether the act of carrying a firearm without being the owner, but under the lawful instruction of the owner, constitutes illegal possession.

Does the legal framework distinguish between unauthorized possession and acting as an agent of the owner in carrying arms?

Whether the imposition of the sentence by the Court of First Instance was appropriate given the circumstances of the case.

Should the context of carrying the firearm as an act of obedience to an authorized instruction have led to a different judicial determination?

The interpretation of "possession" in relation to the intent underlying the custody of the firearm.

Is the absence of criminal intent sufficient to exempt one from being penalized under laws regulating the possession of arms?