Facts:
Cedric Sayco y Villanueva was charged with illegal possession of firearms under the Information before the Municipal Trial Court in Cities (MTCC), Bais City. The Information asserted that on January 3, 1999, in Bais City, Sayco willfully and unlawfully possessed a 9MM SIGSAUER P229 without the proper license or authority. Sayco pleaded “Not Guilty” upon arraignment. The MTCC convicted Sayco, sentencing him to imprisonment and a fine. The Regional Trial Court (RTC) affirmed this decision but modified the penalty. Upon further appeal, the Court of Appeals (CA) upheld the conviction and denied Sayco’s Motion for Reconsideration. Consequently, Sayco filed a Petition for Review on Certiorari with the Supreme Court, challenging the CA’s resolution.
Issues:
1. Whether the lower courts erred in convicting Sayco despite his claim of possessing authority for the firearm.
2. Whether the evidence proved Sayco’s guilt beyond reasonable doubt.
Court’s Decision:
The Supreme Court denied the petition but revised the penalty based on the Indeterminate Sentence Law. The Court held that the Memorandum Receipt and Mission Order presented by Sayco did not exempt him from the requirement of a proper license as per P.D. No. 1866, as amended by R.A. No. 8294. The Court reiterated that a memorandum receipt and mission order cannot replace a duly issued firearms license, and good faith is not a defense in crimes involving illegal possession of firearms, which are considered malum prohibitum.
Doctrine:
The corpus delicti in illegal possession of firearms is the accused’s lack of license or permit to possess or carry the firearm. Memorandum receipts and mission orders cannot replace the requirement for a duly issued firearms license.
Class Notes:
1. **Illegal Possession of Firearms**: To convict someone of illegal possession of firearms under P.D. No. 1866 (as amended by R.A. No. 8294), the prosecution must prove: (a) the existence of the firearm; (b) the accused’s possession of or control over the firearm; (c) the absence of a license or permit to possess or carry the firearm.
2. **Memorandum Receipt and Mission Order**: These documents alone do not suffice as authority to possess or carry firearms outside one’s residence. Regular licenses and special permits issued by the proper authorities are necessary.
3. **Malum Prohibitum Offense**: In crimes that are malum prohibitum (wrong due to being prohibited), the defense of good faith or lack of criminal intent is not applicable. The mere commission of the act is what constitutes the offense.
Historical Background:
The legal framework surrounding the possession and carrying of firearms in the Philippines has evolved significantly over time. Initially, government issuances like the Memorandum Receipt for Equipment and Mission Orders sufficed for specific military and law enforcement personnel to carry firearms. However, landmark cases and statutory amendments have tightened regulations, clarifying that such documents do not exempt individuals from the requirement of obtaining a proper license and permit for firearm possession and carriage as laid out in Presidential Decree No. 1866, as amended by Republic Act No. 8294. This case further cements the principle that mere possession of government-issued documentation without the requisite firearm licenses and permits constitutes illegal possession, a serious crime under Philippine law.
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