Case Summary (G.R. No. 247824)
Charges and Applicable Law
De Guzman was charged with unlawful possession of one .38 caliber Smith and Wesson revolver loaded with ammunition without the required license, violating RA No. 10591. He pleaded not guilty, and his trial focused on the prosecution's obligation to prove beyond reasonable doubt two elements: (1) the existence of the firearm, and (2) the accused's possession or ownership of the firearm without the necessary license.
Prosecution’s Evidence and Testimony
SPO1 Estera testified that on October 22, 2014, he and other police officers were patrolling near White House Market, Pasay City, when they observed people fleeing and saw De Guzman brandishing a revolver and shouting. They arrested De Guzman after he complied with their order to put down the firearm. Following the arrest, the revolver and ammunition were seized, marked in the presence of SPO3 Allan V. Valdez, and turned over to the police. SPO1 Estera’s testimony was the cornerstone of the prosecution’s case.
Defense’s Counter-Narrative
De Guzman’s defense presented a conflicting account, asserting that he was arrested on October 21, 2014, and not on October 22 as alleged. He claimed he was merely preparing dressed chickens for sale at the public market with his sister when a group of men, including SPO1 Estera, approached and harassed him. The alleged cause of arrest was possession of knives used in his trade, not a firearm. De Guzman accused SPO1 Estera of attempting to extort P300,000, threatening to charge him with firearm and drug possession offenses if the money was not paid. Additionally, De Guzman stressed that he owned a licensed .45 caliber firearm and had no reason to carry an unlicensed .38 caliber revolver. Supporting this, he presented his firearm license and permit to carry, along with a certification from the Firearms and Explosives Division.
Regional Trial Court Findings
The RTC convicted De Guzman, holding that the presentation and identification of the firearm and ammunition by SPO1 Estera sufficiently established both elements of illegal possession beyond reasonable doubt. The court relied heavily on the testimony of SPO1 Estera and interpreted De Guzman's admission of not having a license for the .38 caliber revolver as an implicit acknowledgment of guilt. Consequently, De Guzman was sentenced to prision mayor in its medium period, and the firearm was ordered forfeited in favor of the government.
Court of Appeals’ Decision
Upon appeal, the Court of Appeals (CA) affirmed the RTC ruling with modification of the duration of imprisonment. The CA gave significant weight to SPO1 Estera’s testimony and regarded the defense’s witnesses, particularly De Guzman’s sister, as biased and therefore less credible. It also dismissed inconsistencies and irregularities in the prosecution’s presentation as minor, sustaining the conviction on the basis of proof beyond reasonable doubt.
Acquittal on Drug Possession Charge Relevant to the Firearms Case
Notably, the RTC, Branch 110, Pasay City, acquitted De Guzman of illegal possession of dangerous drugs, finding that his arrest lacked legal basis as he was allegedly carrying only knives, not a firearm. The court ruled that the search yielding the alleged drugs was invalid due to the absence of a lawful arrest, rendering the evidence inadmissible as "fruit of the poisonous tree." This ruling indirectly questioned the reliability of the firearm possession facts relied upon in the instant case.
Supreme Court’s Analysis of Proof Beyond Reasonable Doubt
Applying the 1987 Philippine Constitution and pertinent provisions from the Revised Rules on Evidence, the Supreme Court emphasized that criminal conviction requires proof beyond reasonable doubt, which entails moral certainty achieved by the strength of the prosecution’s evidence alone. The prosecution bears the burden of disproving the defense’s position, not merely pointing to its weaknesses.
Evaluation of the Prosecution’s Evidence
The Supreme Court noted the prosecution’s overreliance on the single testimony of SPO1 Estera, whose credibility was challenged due to alleged prior vendetta against De Guzman and accusations of extortion. The Court underscored the insufficiency of relying on one witness without corroboration, especially when the witness’s testimony is self-serving and contradicted by the defense's more plausible narrative.
Deficiencies in the RTC and CA’s Reasoning
Both the RTC and the CA were found to have placed undue weight on the prosecution's lone witness while dismissing or trivializing inconsistencies and infirmities in the evidence. The RTC erroneously construed De Guzman’s declaration about lacking a license for the .38 caliber firearm as an admission of guilt, disregarding his clear explanation of owning a licensed .45 caliber gun. Likewise, the CA overlooked material errors, including incorrect referencing of court branches and dates, indicating a lack of diligence in reviewing the case.
Remaining Inconsistencies
...continue readingCase Syllabus (G.R. No. 247824)
Background and Procedural History
- Jonathan De Guzman y Aguilar (hereafter De Guzman) was charged with illegal possession of a firearm under Republic Act No. 10591, the Comprehensive Firearms and Ammunition Regulation Act, specifically for possession of a Smith and Wesson .38 caliber revolver loaded with four live ammunition rounds without the necessary license or authority.
- De Guzman pleaded not guilty at arraignment and trial ensued.
- The prosecution presented a sole witness, Senior Police Officer 1 Ador Estera (SPO1 Estera), who testified about the arrest and possession of the firearm.
- De Guzman's defense offered a different narrative, accusing SPO1 Estera of false arrest, extortion, and possible vendetta, supported by testimony from De Guzman and his sister, Jessica.
- The Regional Trial Court (RTC), Branch 114, Pasay City, convicted De Guzman in 2017 and sentenced him to prision mayor in its medium period.
- De Guzman appealed to the Court of Appeals (CA); the CA affirmed the RTC's decision with modification in 2018.
- De Guzman filed a Motion for Reconsideration which was denied by the CA.
- De Guzman subsequently filed a Petition for Review on Certiorari before the Supreme Court.
- Separately, the RTC Branch 110 acquitted De Guzman of illegal possession of dangerous drugs, finding the initial arrest invalid since he was not shown to be carrying the firearm.
Facts of the Case
- On October 22, 2014, SPO1 Estera and nine other police officers were on patrol in Pasay City near the White House Market when they observed people running, investigated, and encountered De Guzman allegedly wielding a revolver and shouting as if quarreling.
- The police instructed De Guzman to put down the gun; he complied. SPO1 Estera handcuffed, frisked, and arrested De Guzman, finding the revolver, ammunition, and a sachet of suspected shabu.
- The firearm and ammunition were subsequently marked and turned over to another officer, SPO3 Allan V. Valdez.
- Contrary to the prosecution's version, De Guzman claimed he was arrested on October 21, 2014, while he and his sister were selling dressed chickens at a public market.
- De Guzman denied possession of the firearm, asserted he only had knives used for his business.
- SPO1 Estera allegedly threatened De Guzman at gunpoint, demanded P300,000 to drop charges, and later charged him when he could not pay.
- De Guzman contended that SPO1 Estera had a personal grudge against him arising from a lost cockfight bet and subsequent surveillance.
- De Guzman admitted to owning a licensed .45 caliber firearm, producing official license and permit documents, and denied possessing an unlicensed .38 revolver.
Issues for Resolution
- Whether the prosecution established De Guzman's guilt of illegal possession of a firearm beyond reasonable doubt.
- Whether the lone testimony of SPO1 Estera sufficed to prove the existence of the firearm and De Guzman’s unlawful possession.
- Whether De Guzman's constitutional rights were violate