Evangelista vs The People of the Philippines

FACTS
-Was arrested in Dubai for illegal possession of firearms.
-In order to be released from Dubai, he must surrender the firearms to Capt. Edwin Nadurata (pilot of
flight no. 657 from Dubai to Manila) on January 30, 1996.
-After landing in the Philippines, the firearms were given back to Evangelista and he was arrested at
NAIA for possession of unlicensed firearms.
-Evangelista signed the Customs Declaration Form.
-RTC ruled that he is guilty beyond reasonable doubt for violating Sec. 1, P.D. 1866 as amended (Illegal
Possession of Firearms and Ammunitions) sentencing him to imprisonment of 17 years and four months
to 20 years.
-filed a retrial at the RTC.
-RTC modified the punishment by imprisonment of 6 years to 8 years and a fine of P30,000.
-Filed for a certiorari at the Court of Appeals
ISSUE
-Is Evangelista criminally liable for the illegal possession of firearms?
-Is he still liable if the crime was committed in Dubai and not in the Philippine territory?
HELD
-Yes. Evangelista is criminally liable for the illegal possession of firearms. Since on June 6, 1997, PD 1866
was amended by RA 8294, wherein the new penalty is advantageous to the accused. He was sentenced
to suffer the penalty of imprisonment of six years and one day to eight years and to pay P30,000.
-He is liable for the crime in the Philippines because according to the Customs Declaration Form that he
signed, he was already in possession of the firearms when he landed in the Philippine territory.