De Guzman v. People

 

De Guzman v. People

G.R. No. 240475

July 24, 2019

FACTS:

The RTC and CA convicted Jonathan De Guzman y Aguilar for the crime of illegal possession of a firearm. At around 4:00 p.m. on October 22, 2014, he and nine (9) other police officers were on patrol along Taft Avenue, Libertad, Pasay City. As they were approaching the White House Market, they noticed that people were running away from it. They went to investigate and saw a revolver-wielding man, whom they later identified as De Guzman, shouting as though quarreling with someone. They rushed to De Guzman and introduced themselves as police officers. SPO1 Estera told De Guzman to put down the gun, to which he complied. After picking up the gun, SPO1 Estera asked De Guzman if he had a license to possess it, but De Guzman kept mum. SPO1 Estera then handcuffed and frisked De Guzman, discovering in his possession a sachet of suspected shabu.

ISSUE:

                Whether or not the CA erred in affirming the RTC

HELD:

                Yes. t is not for this Court or any other tribunal to impose technique on or to suggest strategy to a party.1âшphi1 However, as we are now compelled to grapple with the sufficiency of a lone witness' testimony and ascertain if the lower courts were right to take that, and that alone, as enough to convict, our attention is drawn to how the prosecution's evidence is egregiously wanting. The prosecution's manifest deficiencies themselves cannot help but draw attention to how the prosecution could have proceeded more judiciously and how the lower courts have themselves been so credulous. It was also an error for the Regional Trial Court to say that petitioner's own declaration that he had no license to own, possess, or carry a .38 caliber revolver was enough to establish the second element for conviction. This is not merely an inordinate reliance on what is wrongly seen as the defense's weakness, but an outright distortion of what petitioner meant when he said he had no such license.

The defense noted inconsistencies in the prosecution's version of events. Most notably, it emphasized that petitioner was not even arrested on October 22, 2014, as the Information had alleged. There was also no record on the police station's blotter attesting to the conduct of the patrol that supposedly preceded the arrest. Yet, the Court of Appeals dismissed these inconsistencies as minor details. However, these inconsistencies are not mere trivial minutiae. The dates of the supposed criminal incidents and of petitioner's ensuing arrest are matters contained in the Information, and are matters that concern no less than an accused's constitutional right to be informed of the charges against him or her. A proper record of police operations would have helped establish the occurrences upon which petitioner's  being taken into custody were predicated.