Case Summary (G.R. No. L-18766)
Incident Overview
On the morning of December 21, 1960, the Chief of Police in Bacuag apprehended three suspicious individuals loitering in Sitio Pagao, Bacuag. The police confiscated a bag belonging to these individuals, which contained various firearms, ammunition, and tools, including seven false keys. Following the incident, Ramon Lopez, Manuel Buico, and Arturo Caniete faced charges of illegal possession of firearms and illegal possession of false keys in the Justice of the Peace Court of Bacuag.
Legal Proceedings
The accused, upon facing the charges, pleaded guilty to the illegal possession of firearms but not guilty to the charge concerning the false keys. Subsequently, their case was elevated to the Court of First Instance of Surigao del Norte. An information was filed accusing them of illegal possession of false keys, including a master key or picklock. The prosecution alleged that their actions involved deliberate and criminal intent, compounded by the aggravating circumstance of their prior conviction for illegal possession of firearms.
Defense Argument
At trial, Buico and Caniete pleaded guilty, while Lopez maintained his not guilty plea. The trial court heard the prosecution's witness but then dismissed the case, ruling the prosecution had not sufficiently alleged an essential element of the crime of illegal possession of false keys. Specifically, the trial court found lacking the allegation that the keys were "specially adapted to the commission of the crime of robbery," which Lopez's defense argued was critical to the charge.
Legal Basis and Judicial Analysis
Article 304 of the Revised Penal Code outlines the offense of possessing picklocks or similar tools specially adapted for robbery. The essential elements of this crime are: (1) possession of such tools, and (2) that this possession is without lawful cause. The prosecution claimed that Lopez possessed seven false keys, one of which was a picklock, thereby asserting that he met both criteria for illegal possession under Article 304.
The Supreme Court highlighted that a picklock is inherently designed for such criminal purposes, categorizing it as specially adapted to committing robbery. Thus, the claim that the prosecutor had to explicitly describe a picklock's adaptability was unwarranted since the nature of the tool itself suffices for the ch
...continue readingCase Syllabus (G.R. No. L-18766)
Case Citation
- 121 Phil. 805
- G.R. No. L-18766
- Date of Decision: May 20, 1965
Parties Involved
- Plaintiff and Appellant: The People of the Philippines
- Defendant and Appellee: Ramon Lopez
Factual Background
- On December 21, 1960, at 10:00 A.M., the Chief of Police of Bacuag, Surigao del Norte, apprehended three suspicious individuals loitering in Pagao, a sitio of Bacuag.
- The apprehended individuals were carrying a bag containing:
- Three carbines, caliber .30 M1
- One revolver, caliber .22
- Three flashlights with batteries
- Two fully loaded carbine ammunition magazines
- Twelve rounds of carbine ammunition
- One balisong
- A screwdriver
- Seven false keys, including one master key
- Clothing items (trousers, shirts, and a pair of shoes)
Charges Filed
- The three individuals, consisting of Ramon Lopez, Manuel Buico, and Arturo Caniete, were charged with:
- Illegal Possession of Firearms: All three pleaded guilty.
- Illegal Possession of False Keys: They faced a separate complaint; Buico and Caniete pleaded guilty, while Lopez pleaded not guilty.
Proceedings in Lower Court
- After the case of illegal possession of false keys was transmitted to the Court of First Instance of Surigao del Norte, the Assistant Provincial Fiscal filed an information against the three accused.
- The information alleged that on December 21, 1960, the accused had seven false keys, one of which was identified as a picklock or master key, which they possessed without lawful cause.
- The charge cited Article 301 in relation to Artic