G.R. No. 257683 , October 21, 2024
Jimmy B. Puguon, Jr., Petitioner, vs. People of the Philippines, Respondent.

FACTS

On July 2, 2019, the Regional Trial Court (RTC) of Cabarroguis, Quirino, Branch 31, issued Search Warrant No. 0015-2019 against petitioner Jimmy B. Puguon, Jr. The warrant authorized the search of his house for one M16 rifle, one .45 pistol, one .38 revolver, two hand grenades, and corresponding ammunition, alleging a violation of “RA 10951” (a cited error, referring to the Comprehensive Law on Firearms and Ammunitions). Upon execution, two separate Informations were filed against Puguon: Criminal Case No. 3901-2019 for violation of Republic Act (R.A.) No. 10591 (Comprehensive Firearms and Ammunition Regulation Act) and Criminal Case No. 3902-2019 for violation of R.A. No. 9516 (illegal possession of explosives). Puguon filed a motion to quash the search warrant, arguing it was a “scatter-shot warrant” that violated his constitutional right against unreasonable searches and seizures by covering two distinct offenses under different special penal laws. The RTC denied his motion, ruling that illegal possession of firearms, ammunition, and explosives belong to the same class of offenses. The Court of Appeals (CA) affirmed the RTC, relying on the case of Prudente v. Dayrit to hold that R.A. No. 10591 and R.A. No. 9516 are related offenses originating from the same law (Presidential Decree No. 1866) and have the same elements, thus the warrant was validly issued. Puguon elevated the case via a Petition for Review on Certiorari.

ISSUE

Whether Search Warrant No. 0015-2019 violated Puguon’s constitutional right against unreasonable searches and seizures (specifically, whether it is an invalid scatter-shot warrant for allegedly covering two separate offenses).

RULING

The petition is partly meritorious. The Supreme Court ruled that Search Warrant No. 0015-2019 is NOT a scatter-shot warrant and was validly issued. The Court clarified that a scatter-shot warrant is one that does not specify the items to be seized or authorizes the seizure of items connected with multiple distinct offenses. The warrant in question specifically listed the firearms, ammunition, and explosives to be seized. The Court held that the crimes of illegal possession of firearms and ammunition under R.A. No. 10591 and illegal possession of explosives under R.A. No. 9516 are related offenses that can be the subject of a single search warrant. They are offenses of the same species—involving the illegal possession of instruments of violence—and share the same essential elements: (1) the existence of the subject item (firearm, ammunition, or explosive) and (2) the fact that the accused who possessed or controlled it did not have the corresponding license or permit. The Court noted that while R.A. No. 10591 repealed specific sections of P.D. No. 1866, it did not alter the fundamental nature of the offense of illegal possession. Furthermore, the legislative intent behind R.A. No. 10591 , as reflected in Senate records, was to consolidate and harmonize laws on firearms and ammunition, not to treat possession of explosives as an entirely separate, unrelated crime. Therefore, the search warrant, which targeted items falling under these related offenses, was valid. The CA decision was affirmed.