Case Summary (G.R. No. 261670)
Applicable Law
The primary legal framework governing this case is Article 168 of the Revised Penal Code, which penalizes the illegal possession and use of false treasury or bank notes. The relevant provisions were reinforced by the elements established in case law, particularly in Tecson v. Court of Appeals.
Background of the Case
The case originated with an information filed against Gacasan for possession of counterfeit currency amounting to PHP 112,500. The prosecution conducted a test-buy operation after receiving reports about counterfeit bills. Gacasan was arrested during a subsequent operation where he was found in possession of counterfeit 1,000-peso and 500-peso bills.
Prosecution's Case
The prosecution presented evidence, including the certification from Atty. Andrew E. Asperin of the Bangko Sentral ng Pilipinas (BSP), confirming that the seized bank notes were counterfeit. Police Corporal Joseph A. Dalman testified to the events of the buy-bust operation, establishing Gacasan’s direct involvement in delivering the counterfeit money.
Defense Argument
In his defense, Gacasan claimed that he was unknowingly in possession of the counterfeit bills, alleging that they were thrown at him by an unidentified person. He also contended the failure of the prosecution to establish a continuous chain of custody regarding the seized bills, arguing that his knowledge of the contents of the envelope was not proven.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) found Gacasan guilty as charged, concluding that all elements of the crime were satisfied. The RTC sentenced him to an indeterminate penalty of six years of prision correccional to ten years and eight months of prision mayor, with a fine of PHP 7,500.
Court of Appeals Decision
Gacasan appealed to the Court of Appeals (CA), which upheld the RTC’s decision. The CA dismissed Gacasan's defenses as unconvincing and affirmed the conviction, emphasizing that the prosecution had established Gacasan's guilt beyond reasonable doubt.
Supreme Court's Review
Upon review, the Supreme Court affirmed the CA’s decision, emphasizing that the prosecution had proven Gacasan’s knowledge and intent to use the counterfeit bills. The Court reiterated the elements of the crime under Article 168, which were sufficiently established by the evidence presented.
...continue readingCase Syllabus (G.R. No. 261670)
Background of the Case
- The case arises from a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner, Allan Gacasan y Langamin, seeks to review and reverse the Decision and Resolution of the Court of Appeals (CA) in CA-G.R. CR No. 01973-MIN.
- Gacasan was convicted for illegal possession and use of false bank notes, specifically counterfeit Philippine currencies, in violation of Article 168 of the Revised Penal Code.
Antecedents
- An Information was filed against Gacasan, alleging that on November 10, 2018, he unlawfully possessed counterfeit Philippine currency amounting to PHP 112,500.
- The counterfeit bills included 100 pieces of 1000-peso bills and 25 pieces of 500-peso bills.
- Gacasan pleaded not guilty upon arraignment, and the case proceeded to trial.
Prosecution's Case
- The Criminal Investigation Detection Group (CIDG) conducted a test-buy operation after receiving reports of counterfeit bills in Bukidnon.
- A buy-bust operation on November 10, 2018, resulted in Gacasan's arrest after he delivered the counterfeit bills to the poseur buyer, Police Corporal Joseph A. Dalman.
- Atty. Andrew E. Asperin of the Bangko Sentral ng Pilipinas confirmed the bills were counterfeit.
Defense's Arguments
- Gacasan claimed he was resting at a waiting shed when an unknown person threw counterfeit money at him.