People v.

Purisima

(Keywords: 3 Judges)

Facts:
There were 26 petitions for review filed by the people of Philippines.
These petitions involve three courts of first instance, namely: Court of first instance
of manila presided by Hon. Amante P. Purisima, Court of first instance of manila
presided by Hon. Maximo A. Maceren and the court of first instance of samar
presided by Hon. Wenceslao M. Polo. The three accused are Porfirio Candelosas Y
Duran, Reynaldo Laqui Y Aquino, and Panchito Refuncion. 3 persons were accused of
illegal possession of firearms on 3 different cases. The 3 judges presiding in each
case all decided to dismiss the case because of a defect in the evidence which
shows that no malicious intent was shown by offenders during the commission of
the act. Specifically, that the carrying outside of the accuseds residence of a
bladed, pointed or blunt weapon is in furtherance or on the occasion of, connected
with or related to subversion, insurrection, or rebellion, organized lawlessness or
public disorder. Thereafter, the people filed petitions for review of the decisions of
the courts of first instance of Manila and Samar. The people through the solicitor
general contend that in statutory offenses the intention of the accused who
commits the act is unimportant that it is enough that the prohibitive act is done
voluntarily.
Issue:
Whether or not to grant the 26 petitions asking for the accused to be
convicted by P.D. 9 for the crime of illegal possession of firearms.
Held:
No. That there is ambiguity in the presidential decree is manifest from
the conflicting views which arise from its implementation. When ambiguity exists, it
becomes a judicial task to construe and interpret the true meaning and scope of the
measure of penal statutes. And in order for us to ascertain the intent and reason for
P.D. 9, first we need to find out the presence of events that led to the enactment of
P.D. 9. The state of martial law in the country pursuant to Proclamation 1081 and
the alleged fact that subversion, rebellion, insurrection , lawless violence,
criminality, chaos and public disorder mentioned in proclamation 1081 are
committed and abetted by the use of firearms and explosives and other deadly
weapons. It is to be presumed that when P.D. 9 was promulgated by the president of
the republic there was no intent to work a hardship or an oppressive result, a
possible abuse of authority or act of oppression, arming one person with a weapon
to impose hardship on another, and so on. The purpose is not to enable a guilty
person to escape punishment through a technicality but to provide a precise
definition of forbidden acts. Wherefore, we deny these 26 petitions for review and
we affirm the orders of respondent judges.