Case Summary (G.R. No. 182694)
Background of the Case
Igmidio Madrigal was charged with two distinct offenses in the Regional Trial Court of San Pedro, Laguna, related to the illegal possession of a .38 caliber revolver during the election period in 1998. The charges were violations of Presidential Decree (PD) 1866, amended by Republic Act (RA) 8294, and violations of the Omnibus Election Code, as amended by RA 7166. The factual basis for the charges revolved around Madrigal's possession of an unlicensed firearm and live ammunition without the requisite permit during a designated election period.
Trial Court Proceedings
Madrigal pleaded not guilty upon arraignment. The Regional Trial Court found him guilty beyond reasonable doubt in both cases. He was sentenced in Criminal Case No. 1026-SPL to an indeterminate prison term of two years, eleven months, and ten days, up to five years, four months, and twenty days, along with a fine of P15,000 for violating PD 1866. In Criminal Case No. 1025-SPL, he received a sentence of one to three years, along with accessory penalties, for violating the election gun ban.
Appeal to Court of Appeals
Madrigal subsequently appealed the decision, questioning the sufficiency of evidence presented against him and his conviction under both criminal statutes. The Court of Appeals upheld the RTC's decision regarding his guilt but modified the penalty under Criminal Case No. 1026-SPL, reducing his prison term.
Supreme Court Proceedings
In his petition for review on certiorari, Madrigal contended his acquittal of both offenses, specifically arguing against his convictions considering the provisions of RA 8294, which states that an individual cannot be concurrently convicted for illegal possession of firearm if another crime has taken place.
Supreme Court Decision
The Supreme Court largely agreed with Madrigal's assertions related to the overlapping charges. Upholding the factual findings regarding his possession of an unlicensed firearm, the Court maintained respect for the lower courts’ factual determinations. However, it recognized that under Section 1 of RA 8294, Madrigal could not be convicted for illegal possession of a firearm while also being convicted of violating the election gun ban in the same incident. The Court reference
...continue readingCase Syllabus (G.R. No. 182694)
Case Background
- The case revolves around petitioner Igmidio Madrigal who was charged with possession of an unlicensed firearm during the 1998 election period.
- The charges were filed in the Regional Trial Court (RTC) of San Pedro, Laguna, Branch 93.
- Two separate criminal charges were filed against Madrigal:
- Violation of Presidential Decree (PD) 1866, as amended by Republic Act (RA) 8294 (Illegal Possession of Firearm).
- Violation of the Omnibus Election Code, as amended by RA 7166 (Gun Ban).
Factual Allegations
- The charges stemmed from an incident on March 31, 1998, when Madrigal was found in possession of a .38 caliber Smith & Wesson revolver without a serial number and live ammunition.
- The first charge (Criminal Case No. 1025-SPL) accused Madrigal of possessing the firearm without a permit from the Commission on Elections (COMELEC) during the election period from January 11 to June 10, 1998.
- The second charge (Criminal Case No. 1026-SPL) accused him of possessing an unlicensed firearm without the required permit from lawful authorities.
Trial and RTC Decision
- Igmidio Madrigal pleaded not guilty at his arraignment.
- After a trial on the merits, the RTC rendered its judgment:
- In Criminal Case No. 1026-SPL, Madrigal was found guilty of violating PD 1866 and was sentenced to an indeterminate penalty ranging from two years, eleven months, and ten days to five years, four months, and twenty days