**Facts:** On 23rd August 1988, in Mendez, Cavite, Santiago Evaristo and Noli Carillo were apprehended for illegally manufacturing, repairing, and possessing firearms and ammunition without the necessary permits. This incident followed a routine patrol by a contingent of the Philippine Constabulary and the Integrated National Police in Barangay III, Mendez, Cavite, where they investigated successive gunfire bursts. During this patrol, they encountered Carillo with a concealed weapon and, upon Evaristo’s consent, discovered various firearms and ammunition in his house. Both defendants contended that they were unlawfully detained and the items were planted by the authorities.
Procedurally, the case progressed to the Regional Trial Court of Trece Martires, Cavite, where, after a trial where both parties presented evidence and witnesses, the court found the defendants guilty as charged, sentencing them to life imprisonment. The appellants then moved to the Supreme Court, contesting the legality of the evidence seized and the credibility of the arresting officers’ testimonies.
**Issues:**
1. Whether the search that yielded the firearms and ammunition was lawful.
2. Whether the uncovered firearms fall under the prohibition of Presidential Decree No. 1866.
3. Whether the testimonies of the arresting officers were credible and sufficient to support a conviction.
**Court’s Decision:**
1. **On the legality of the search:** The Supreme Court held that the search was lawful under the “plain view” doctrine and incidental to a lawful arrest, thus upholding the admissibility of the seized firearms and ammunition.
2. **On the coverage of Presidential Decree No. 1866:** The Court ruled that the decree does not distinguish between operational and non-operational firearms, thereby finding that possession of any part of a firearm, functional or not, violates the decree.
3. **On the officers’ testimonies:** The Court found no inconsistencies in the testimonies that would merit disbelief, emphasizing that the defense did not present any compelling reason for the peace officers to fabricate their accounts.
**Doctrine:** The case reiterated the doctrine that objects falling in the “plain view” of an officer legally positioned to have that view are subject to seizure without a warrant. Moreover, it clarified that Presidential Decree No. 1866 covers any firearm or part thereof, regardless of its operational condition.
**Class Notes:**
– **Plain View Doctrine:** Allows the seizure of objects without a warrant when they are in plain sight of an officer who has the legal right to be in the position to have that view.
– **Presidential Decree No. 1866:** The possession of any firearm, or part of a firearm, without appropriate authorization violates this decree, irrespective of the firearm’s operational status.
– **Warrantless Arrest:** Legal under certain conditions, such as when the officer has a direct observation of an offense or has immediate knowledge that a crime has been committed by the person being arrested.
**Historical Background:** The case underscores the rigorous enforcement of firearm regulations in the Philippines, reflecting the country’s stance against unauthorized possession and manufacture of weapons, which is a matter of significant concern due to its implications for public safety and order.
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