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penal law topic.

People of the Philippines v. Walpan Ladjaalam

GR Nos. 136149-51

Facts:

 On September 24, 1997, the Zamboanga City police conducted a raid against Ladjaalam upon
the issuance of search warrant. When they came close in to the gates of the house of accused,
they were met with a rapid burst of gunfire prompted by appellant Ladjaalam. That same day,
they succeeded in arresting appellant.
 Walpan Ladjaalam was convicted with the crime of Multiple Attempted Homicide with Direct
Assault, and a separate crime of Illegal Possession of Firearms and Ammunition penalized under
PD 1866 as amended by RA 8294.
 The Office of the Solicitor General disagreed with the crime and punishment of accused
contending that the trial court should not have applied the new law—RA 8294 which states that
unlawful possession of firearms is punishable provided that no other crime was committed. The
old law, PD 1866 being the applicable law which penalizes simple illegal possession of firearms
even if another crime is committed at the same time.
 Trial Court on the other hand ruled that accused was liable for illegal possession of firearms in
addition to the crime of homicide with direct assault. It construed that the words “no other
crime” refers only to homicide and murder, both of which with illegal possession of firearms is
considered an aggravating circumstance. Hence, if a crime other than murder or homicide is
committed, a person may still be convicted of illegal possession of firearms. In this case, the
“other crime committed” was direct assault with multiple attempted homicide; hence, the trial
court found appellant guilty of illegal possession of firearms.

Issue: Whether or not the interpretation of the Office of the Solicitor General and Trial Court are
meritorious so as to render accused guilty of illegal possession of firearms as a separate crime.

Ruling:

No. The Supreme Court did not accept the interpretation of both the Office of the Solicitor General and
the lower court on the ground that they have ignored the plain language of the statute. A simple reading
of RA 8294 shows that if an unlicensed firearm is used in the commission of any crime, there can be no
separate offense of simple illegal possession of firearms. Hence if the “other crime” is murder or
homicide, illegal possession of firearms becomes merely an aggravating circumstance and not a separate
offense. Since direct assault with multiple attempted homicide was committed by the accused, he can
no longer be held liable for illegal possession of firearms.

Moreover, penal laws are construed liberally in favor of the accused. The plain meaning of RA 8294’s
simple language is most favorable to herein appellant. Verily, no other interpretation is justified, for the
language of the new law demonstrates the legislative intent to favor the accused.

The OSG’s contention that the old law should apply is not tenable because when the crime was
committed on September 1997, PD 1866 had already been expressly superseded by RA 8294 which took
effect on July 1997. And in the contention that the phrase “no other crime” should be limited to murder
or homicide is not justified. The law is clear: the accused can be convicted of simple illegal possession of
Note: Yung highlighted optional po na ilagay since hindi siya vital sa rling na connected sa hinahanap sa
penal law topic.

firearms, provided that “no other crime was committed by the person arrested.” If the intention of the
law in the 2nd paragraph refers only to homicide and murder, the law should have expressly provided it.