GR 253930; (July, 2022) (Digest)
G.R. No. 253930 . July 13, 2022.
PAULO CASTIL Y ALVERO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
This case originated from a buy-bust operation targeting Sandra Young for illegal drugs. Police officers, acting on a tip, arranged a meeting. Young arrived driving a vehicle with petitioner Paulo Castil y Alvero as a companion. The poseur-buyer boarded the vehicle, and an alleged drug transaction occurred. When the officer attempted an arrest, Young sped away, leading to a struggle. Petitioner and the officer wrestled inside the moving car until it crashed. Back-up officers subdued petitioner. A subsequent body search yielded a Norinco cal. 9mm pistol loaded with five live rounds from petitioner’s waist, along with suspected shabu. Petitioner was charged with Illegal Possession of Firearms under RA 10591. During trial, the prosecution presented the arresting officer who testified to the recovery and marking of the firearm. Petitioner denied the charge, claiming he was merely assisting a friend with a stalled car and was arbitrarily arrested without any firearm being found on him.
ISSUE
The core issue is whether the prosecution proved petitioner’s guilt for illegal possession of firearms beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The offense of illegal possession of firearms under RA 10591 has two elements: (1) the accused possessed a firearm, and (2) the accused did not have a license or permit to possess it. The Court found both elements established. The positive and credible testimony of PO1 Rebustes, who recovered the firearm from petitioner’s person during a lawful search incident to a lawful arrest, prevailed over petitioner’s bare denial. Denial, being inherently weak, cannot overcome positive identification. Crucially, petitioner judicially admitted during cross-examination that he had no license or permit to own or possess any firearm and had never applied for one. This admission, made in open court, conclusively established the second element of the crime. The Court emphasized that such a judicial admission requires no further proof and is binding on the declarant. Petitioner’s defense of frame-up or planting was also rejected for lack of clear and convincing evidence of any ill motive on the part of the arresting officers. Therefore, his guilt was proven beyond reasonable doubt. The penalty imposed by the lower courts was affirmed as within the range provided by law.