G.R. No. 261612 , August 14, 2024
ARSENIO MANAGUELOD Y TANDAYU, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Arsenio Managuelod y Tandayu was charged with violation of Batas Pambansa Blg. 6 in relation to Republic Act No. 7166 (the Omnibus Election Code) and COMELEC Resolution No. 10446. The Information alleged that on March 18, 2019, in Tuguegarao City, during the election period, Managuelod willfully and unlawfully possessed a knife, a deadly bladed weapon, outside his residence without a valid COMELEC exemption. The incident occurred when he was seen climbing the concrete fence and railings of the Hometel Inn, prompting the manager to call the police. Upon arrest, a knife with a holster was recovered from his sling bag. At trial, the prosecution presented police officers who testified to the arrest and seizure. The defense presented Managuelod, who claimed he was merely urinating beside the road when accosted by men who arrested and brought him to the police station. The Regional Trial Court found him guilty, sentencing him to imprisonment and disqualification from public office and suffrage. The Court of Appeals affirmed the conviction. Managuelod filed the present petition, arguing, among others, the incredibility of the prosecution’s version, the failure to present the hotel manager, the necessity of the knife for his profession as a driver, the Hometel Inn being a private place, and the inadmissibility of the seized knife due to alleged lack of markings.

ISSUE

Whether the Court of Appeals erred in affirming Managuelod’s conviction for illegal possession of a deadly weapon during the election period.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court clarified that the applicable law is not Batas Pambansa Blg. 6, whose rationale (curtailing disorder during martial law) had ceased, but Section 32 of Republic Act No. 7166 in relation to the Omnibus Election Code and COMELEC Resolution No. 10446. Under these election laws, it is unlawful to carry firearms or other deadly weapons outside one’s residence or place of business during the election period unless authorized by the COMELEC. The Court found that Managuelod was carrying a knife in a public place (Hometel Inn, defined as a public place under the law) during the 2019 election period without COMELEC authority. His claim that the knife was necessary for his livelihood as a driver was unsubstantiated, as drivers are not among those statutorily authorized to possess deadly weapons during the election period. The Court upheld the credibility of the police officers’ testimonies and the admissibility of the knife as evidence, noting the presumption of regularity in the performance of official duty and that the marking on the fabric handle may have faded over time. The factual findings of the lower courts were sustained, as no relevant facts were overlooked that would change the outcome.