The Supreme Court ruled that a certification from a local Philippine National Police (PNP) office is admissible as evidence to prove the lack of a firearm license, reinforcing the responsibility of the accused to prove lawful possession. This decision clarifies the acceptable standards of proof in cases involving illegal possession of firearms and emphasizes that possessing a license is a matter of personal knowledge that the accused must demonstrate. The ruling confirms the prosecution’s ability to establish a prima facie case based on the best available evidence, shifting the burden of proof to the defendant.

Guns, No License: When Can Local Certifications Prove Illegal Firearm Possession?

This case revolves around Cayetano Capangpangan, who was convicted of illegal possession of firearms, ammunitions, and explosives. The key legal question is whether a certification from the Iligan City PNP is sufficient proof that Capangpangan did not have a firearms license. Capangpangan argued that the certification was inadequate, as it did not come from the Firearms and Explosives Unit at Camp Crame, the central repository for all firearms licenses. The prosecution presented the certification from the Iligan City PNP, attesting that there was no record of a firearms license under Capangpangan’s name within their jurisdiction.

During the trial, Capangpangan admitted the existence and content of this certification. The Supreme Court invoked Section 4 of Rule 129 of the Revised Rules on Evidence, emphasizing that admissions made during proceedings do not require further proof. Since Capangpangan did not argue that the admission was made through palpable mistake, he could not later challenge the certification’s validity. The Court referenced that “an admission, verbal or written, made by a party in the course of the proceedings in the same case, does not require proof. The admission may be contradicted only by showing that it was made through palpable mistake or that no such admission was made.”

The Court addressed Capangpangan’s argument that the certification’s limited scope to Iligan City was a basis to disregard the evidence. It firmly rejected this, stating that the prosecution had presented the best available evidence. Considering the negative averment of lacking a license, the Court determined that proving such rests primarily on the accused due to its personal nature. American case law supports this position, stating,

Where the negative of an issue does not permit of direct proof, or where the facts are more immediately within the knowledge of the accused, the onus probandi rests upon him…it is not incumbent on the prosecution to adduce positive evidence to support a negative averment the truth of which is fairly indicated by established circumstances.

Therefore, because Capangpangan possessed the information about his firearm license, it was his responsibility to provide evidence to contradict the prosecution’s certification. The Court gave considerable weight to the lower court’s assessment of witness credibility and factual findings, in addition to the admitted certificate. Significant discrepancies in the testimonies of Capangpangan and his witnesses also undermined his defense, particularly regarding where the firearms were discovered. The defense’s inconsistencies played a crucial role in affirming the trial court’s and Court of Appeals’ conviction decisions. It is the domain of the trial court to weigh the value of such.

Finally, the Court emphasized that failing to present corroborating witnesses or documentary evidence, such as photographs of the search, does not invalidate the prosecution’s case. It’s within the prosecution’s discretion to decide which witnesses to present, and the defense had the opportunity to subpoena those witnesses but chose not to. Considering all evidence, the Supreme Court denied Capangpangan’s petition, affirming the lower court’s decision and reinforcing standards to convict violators of Republic Act No. 10591, otherwise known as the Comprehensive Firearms and Ammunition Regulation Act.

FAQs

What was the key issue in this case?	The primary issue was whether the certification from the Iligan City PNP was sufficient to prove that Cayetano Capangpangan did not possess a license to own firearms. The court ruled that it was, especially because Capangpangan had admitted to the certification’s contents during trial.
Why was the local PNP certification deemed sufficient evidence?	Because the existence of a firearm license is a matter of personal knowledge, the court expects the defendant to readily present it if they have one. Also, Capangpangan admitted to the contents of the certification.
What is the significance of admitting to the certification’s content during trial?	Under Section 4 of Rule 129 of the Revised Rules on Evidence, admissions made during trial do not require further proof. This meant Capangpangan couldn’t later dispute the authenticity or accuracy of the certification unless he could prove it was admitted under palpable mistake.
What does “best available evidence” mean in this context?	“Best available evidence” refers to the most reliable form of evidence accessible to the prosecution to demonstrate a fact. In this case, the certification from the local PNP office responsible for firearm records in the area was the best available evidence to show Capangpangan did not have a license.
Why was the burden of proof placed on Capangpangan?	The court stated that the negative allegation of lacking a license rests primarily on the accused because it is a matter of personal knowledge and readily disproven with evidence by the accused.
Were there any discrepancies in the defense’s testimony?	Yes, significant discrepancies were found, particularly regarding the location where the firearms were allegedly discovered, the individuals present, and their activities at the time. These inconsistencies impacted the credibility of the defense’s case.
Why was the absence of corroborating witnesses or documentary evidence not critical?	The court clarified that the prosecution has the prerogative to decide which witnesses to present. Additionally, the defense had the opportunity to subpoena other witnesses but did not, suggesting that the witnesses’ testimonies might not have supported their case.
What is the main takeaway from this Supreme Court decision?	The primary takeaway is that in cases of illegal possession of firearms, the burden of proving legal authority to possess firearms falls heavily on the defendant. Additionally, it reiterated the admissibility of certifications of local authorities of record, where the negative averment can be demonstrated by positive certification.

This case underscores the importance of properly documenting and securing licenses for firearms. It clarifies what evidence is needed to prove the lack of a license in prosecution for the Comprehensive Firearms and Ammunition Regulation Act and also sets a precedent on how the courts see the admissibility of specific certifications from authorities. This reinforces the State’s regulatory authority to fully investigate crimes and penalize the commission of these offenses.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Cayetano Capangpangan v. People, G.R. No. 150251, November 23, 2007