G.R. Nos. 84332-33. May 8, 1996.
People of the Philippines vs. Reynaldo Evangelista.

FACTS

Accused-appellant Reynaldo Evangelista had an altercation with Efren Arceo after Arceo destroyed part of Evangelista’s mother’s house. The following day, barangay officials attempted to mediate, but Evangelista confronted and threatened Arceo. That night, while Arceo and his wife Priscilla slept, a gunshot erupted. Priscilla saw a man fleeing and, upon checking, found her husband fatally wounded. She identified the fleeing man as Evangelista based on his body contour, having known him as a former neighbor.
An investigation led to Evangelista’s apprehension. Police investigator Pat. Ladia claimed Evangelista confessed and led them to recover a homemade firearm (paltik) from a friend. Ballistics tests confirmed the fatal bullet was fired from that gun. Evangelista was charged with Murder and Illegal Possession of Firearms under P.D. No. 1866. The trial court convicted him on both counts, sentencing him to reclusion perpetua for murder and an additional penalty for the firearms violation.

ISSUE

The primary issues were: (1) whether the prosecution proved Evangelista’s guilt for murder beyond reasonable doubt, and (2) whether his conviction for illegal possession of firearms was valid.

RULING

The Supreme Court affirmed the murder conviction but acquitted Evangelista of the firearms charge. On the murder charge, the Court found the circumstantial evidence sufficient to establish guilt beyond reasonable doubt. The evidence formed an unbroken chain leading to the conclusion that Evangelista was the perpetrator. This included his motive from the prior altercation, his threat against the victim, Priscilla’s credible identification of him as the fleeing assailant based on familiarity, and the ballistics match linking the recovered paltik to the crime. The Court found no reason to disturb the trial court’s assessment of witness credibility.
However, the Court reversed the conviction for illegal possession of firearms. It held that for a conviction under P.D. No. 1866, the prosecution must allege and prove that the firearm was unlicensed. The Information failed to allege that the paltik was unlicensed, which is a vital element of the offense. The Court rejected the Solicitor General’s argument that a paltik is inherently unlicensable, clarifying that the case cited did not establish that such firearms can never be licensed. The absence of this essential allegation in the Information was a fatal defect that warranted acquittal on that charge. The indemnity for the victim’s heirs was increased to P50,000.00.