Case Summary (G.R. No. 150251)
Charges and Prior Proceedings
Capangpangan was charged via an Information detailing the illegal possession of numerous firearms, ammunition, and explosives without legal authority. After entering a plea of not guilty, the case proceeded to trial. The Regional Trial Court (RTC) convened in Iligan City to hear the case, which was docketed as Criminal Case No. 03-6752.
Evidence for the Prosecution
The prosecution's evidence included a valid search warrant executed by National Bureau of Investigation (NBI) agents and military personnel, which led to the discovery of firearms hidden in the ceiling of Capangpangan’s house. Various items, including hand grenades and ammunition, were seized, with an inventory prepared and signed by witnesses, including Capangpangan himself.
Evidence for the Defense
Capangpangan's defense claimed that the firearms were found in an abandoned hut and not in his house, thus asserting that the search was unlawful. The defense contended that the military officials did not follow proper protocols after finding the firearms and highlighted inconsistencies in witness testimonies regarding the sequence of events leading to his apprehension.
Ruling of the Regional Trial Court
On August 5, 1999, the RTC found Capangpangan guilty of the charges, imposing a sentence of four years, two months, and one day to eight years of imprisonment, alongside the confiscation of the firearms. The court credited the prosecution’s evidence and emphasized the presumption of regularity in the actions of law enforcement officials, finding the defense’s claims implausible.
Ruling of the Court of Appeals
Capangpangan appealed the RTC’s decision, primarily challenging the credibility of witnesses. The Court of Appeals affirmed the RTC's ruling, stating that the lower court's factual findings were sound and supported by the evidence presented. It also noted that the certification from the Philippine National Police indicated that Capangpangan had no license for the seized firearms, thereby concluding that he violated the provisions of Presidential Decree No. 1866.
Key Issues Raised on Appeal
In his petition, Capangpangan raised several issues, including the absence of adequate proof of his lack of a firearms license, challenges to the credibility of prosecution witnesses, and assertions that the firearms were not found in his residence. He argued that the trial court erred in finding him guilty beyond a reasonable doubt.
The Court's Ruling on Credibility and Evidence
The Supreme Court held that the assessment of witness credibility is primarily the domain of the trial court, whose fi
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Case Background
- The case concerns a Petition for Review on Certiorari under Rule 45.
- The petitioner, Cayetano Capangpangan, contests the July 12, 2001 Decision of the Court of Appeals (CA) in CA-G.R. CR No. 23655.
- The CA affirmed Capangpangan's conviction for illegal possession of firearms, ammunitions, and explosives as per Presidential Decree No. 1866, as amended, in Criminal Case No. 03-6752.
- The case also involves the CA's September 13, 2001 Resolution, which denied the petitioner's motion for reconsideration.
Charges and Initial Proceedings
- Capangpangan was charged with violating PD 1866, specifically for possessing various firearms and ammunition without the necessary licenses or permits.
- The Information alleged that on July 1, 1997, in Tagoloan, Lanao del Norte, Capangpangan unlawfully possessed:
- Five live hand grenades.
- Eight Garand clips.
- Sixteen Garand clips without ammunition.
- Various calibers of ammunition and firearms, including a defaced shotgun and rifles.
- Capangpangan pleaded not guilty to the charges.
Evidence Presented
Prosecution's Evidence
- The National Bureau of Investigation (NBI) agents, with military personnel, executed a valid search warrant at Capangpangan's residence.
- During the search, agents discovered an ammunition box containing firearms and ammunition hidden in the ceiling.
- An inventory was prepared in the presence of Capangpangan and his wife, which they signed, acknowledging the seizure.
Defense's Evidence
- Capangpangan argued that the search was illegal, claiming the seized items were found in an uninhabited hut rather than his house.
- Witnesses for the defense claimed that on t