Laila C.

Lasam

G.R. No. 168644 February 16, 2010

BSB GROUP, INC., represented by its President, Mr. RICARDO
BANGAYAN, Petitioner,
vs.
SALLY GO a.k.a. SALLY GO-BANGAYAN, Respondent.
FACTS:
Sally Go, commonly known as Sally Go-Bangayan, is the accused-
appellant in this case. Ricardo Bangayan filed a complaint against Sally Go
for qualified stealing. Sally Go worked as a cashier for BSB Group, Inc.,
where she was in charge of accepting and recording payments from clients.
According to the lawsuit, Sally Go failed to turn over client checks to the
company and instead deposited them into her personal bank account. The
uncontested evidence led the assistant city prosecutor to recommend that
Sally Go be charged with qualified stealing. The Manila, Branch Regional
Trial Court received a charge against Sally Go. The information's
incriminating part charged Sally Go with knowingly, unlawfully, and
criminally stealing funds from the BSB Group of Companies without the
owner's permission. At her arraignment, Sally Go entered a negative plea.
In order to provide evidence on Sally Go's bank accounts, the prosecution
requested that subpoenas be issued to the managers or records
custodians of Asian Savings Bank and Security Bank's Divisoria Branch.
Sally Go claimed that the complaint-affidavit omitted the reference to the
aforementioned bank account when she filed a move to revoke the
subpoena sent to Metrobank. Sally Go's move to quash was dismissed by
the trial court due to its lack of merit. Elenita Marasigan, a Security Bank
staffer, testified for the prosecution to demonstrate that Sally Go placed the
cheques into her personal account. Sally Go filed a Motion to Suppress
before the testimony could end, requesting that Marasigan's testimony and
the supporting records pertaining to the Security Bank account be
excluded. Sally Go's move to suppress was turned down by the trial court.
The orders of the trial court were overturned and set aside by the Court of
Appeals after Sally Go filed a petition for certiorari. The testimony of
Marasigan was ordered to be removed from the records by the Court of
Appeals. In a Petition for Review submitted to the Supreme Court, BSB
Group, Inc. contended that the Court of Appeals erred in overturning the
orders of the trial court. The evidence that the Supreme Court said should
Laila C. Lasam

be withheld breached bank deposit confidentiality and was not relevant to

the case. The money that Sally Go is accused of stealing was the focus of
the lawsuit, according to the Supreme Court, not the checks or the bank
account. The Supreme Court underlined that bank deposits are legally
required to remain completely secret. The Supreme Court upheld the Court
of Appeals' ruling and dismissed the petition.
Issue:
1. Whether the testimony and documentary evidence regarding Go's
bank account are relevant and admissible.
2. Whether the evidence violates the confidentiality of bank deposits.
Ruling:
1. The Court of Appeals' ruling was upheld by the Supreme Court. Since
the criminal information accused Go of stealing cash rather than checks,
evidence pertaining to her bank account was deemed insignificant to the
case.
2. Evidence breached the legally protected confidentiality of bank deposits.
Both documentary evidence and testimony were declared inadmissible.
In a theft case, evidence must be directly related to the reality at hand,
which in this example is the purported theft of cash. Evidence pertaining
to checks on Go's bank account was considered superfluous and
inconsequential. According to the law, bank deposit confidentiality is a
fundamental state policy in the Philippines. Evidence that attempted to
investigate a bank deposit account was admitted, which went against
the law's protections of confidentiality and privacy. Until Congress does
otherwise, all doubts should be dispelled in favor of maintaining the
ultimate confidentiality of bank deposits.
G.R. No. 174673
REPUBLIC OF THE PHILIPPINES, Petitioner,
vs.
FE ROA GIMENEZ AND IGNACIO B. GIMENEZ, Respondents.
FACTS:
The Republic of the Philippines is suing the Gimenez Spouses in an effort
to reclaim illicit income. In order to obtain reconveyance, reversion,
Laila C. Lasam

accounting, restitution, and damages, the Republic filed a complaint

against the Gimenez spouses. According to the Republic, the Gimenez
Spouses became wealthy by acting as spies, go-betweens, or nominees for
former President Ferdinand E. and First Lady Imelda Marcos. The Republic
used witness testimony and documentary evidence to support its claims
about the Gimenez Spouses' income, business interests, positions held,
and transactions throughout the trial. But the Sandiganbayan declared the
Republic's Formal Offer of Evidence waived since it was not submitted in
the allotted time. The Gimenez Spouses' Motion to Dismiss on a demurrer
to evidence was granted by the Sandiganbayan.
Issue:
Whether the Sandiganbayan erred in ruling that the evidence presented by
the Republic lacked probative value.
Ruling:
The Republic won the case at the Supreme Court. The Sandiganbayan
dismissed the case with significant abuse of discretion, according to the
court. The Court underlined that procedural restrictions should not be
employed to obstruct or postpone the administration of justice, particularly
when it comes to matters involving the recovery of illicitly acquired riches.
Even though the Formal Offer of Evidence was not timely made, the Court
decided that the Sandiganbayan should have taken the Republic's
testimony evidence into consideration. The Sandiganbayan made a
mistake, according to the Court, in ruling that the documentary evidence
had no probative value because the documents were either certified true
copies of the original documents or public records.

HEIRS OF JOSE V. LAGON et al. v ULTRAMAX HEALTHCARE et al.

G.R. No. 246989, December 07, 2020
Facts:
The Heirs of Jose V. Lagon brought a complaint against Ultramax
Healthcare Supplies, Inc. in order to have the new titles that Ultramax had
granted revoked. The Lagon Spouses asserted that a forged deed of
absolute sale was the reason for the cancellation and transfer of titles.
According to Ultramax, the Lagon Spouses gave the homes to Ultramax
after using them as collateral for a loan. The Lagon Spouses provided
evidence during the trial to show that the deed of absolute sale's signatures
Laila C. Lasam

were fake. A Deed of Absolute Sale and a Deed of Mortgage, both dated
December 2009, were requested to be admitted by Ultramax. The records
were irrelevant, according to the Lagon Spouses, who complained. The
Lagon Spouses claimed that the trial court had committed a serious abuse
of discretion in their petition for certiorari to the Court of Appeals. The
petition was denied by the Court of Appeals, which held that the trial court
had the right to accept or reject evidence that might have an impact on the
case's outcome.
Issue:
Whether the Court of Appeals erred in finding that the trial court did not
gravely abuse its discretion in allowing the examination of the Deed of
Mortgage.
Ruling:
The trial court did not misuse its discretion, the Supreme Court ruled,
concurring with the Court of Appeals. The Supreme Court upheld the Court
of Appeals' ruling and dismissed the petition. Procedures ought to be
followed in a way that advances substantial justice and does not impede
the completion of case adjudication. If there is a valid reason, more
evidence may be introduced during the trial. The purpose of introducing the
Deed of Mortgage was to contrast the signatures within it with the
purportedly falsified signatures on the Deed of Absolute Sale under
scrutiny. The Deed of Mortgage was not categorically declared inadmissible
by the trial court. The mortgage deed served as pertinent evidence to
determine the likelihood that the deed of absolute sale was forged.
Social Justice Society vs. Atienza Feb 13, 2008
Facts:
The petitioners requested a mandamus order to compel the
respondent, Hon. Ordinance No. 8027 to be enforced by Jose L. Atienza,
Jr., the City of Manila's mayor at the time. The Pandacan area was
reclassified from industrial to commercial via Ordinance No. 8027, which
also required any enterprises that were not permitted to continue operating
in the region to stop within six months. The Department of Energy (DOE)
and the oil companies—Petron Corporation, Pilipinas Shell Petroleum
Corporation, and Chevron Philippines, Inc.—filed requests to intervene and
Laila C. Lasam

to have the decision reconsidered. The oil firms contended that since the
ordinance's implementation directly impacts their operations and property
rights, they must intervene. The DOE asserted that the ordinance violates
its sole jurisdiction over energy resources.
Issue:
1. Whether the oil companies and DOE should be allowed to intervene
in the case.
2. Whether the injunctive writs issued by the RTC impede the
enforcement of the ordinance.
Ruling:
Because the oil firms and DOE presented new and previously
unconsidered issues and arguments, the Supreme Court granted their
intervention. Because the RTC's injunctive writs were not founded on a
compelling case of unconstitutionality, the Court determined that they do
not prevent the ordinance from being enforced. The Court found that
because Ordinance No. 8119 and Ordinance No. 8027 can be reconciled
and have different application areas, they are not impliedly repealed by
each other. The Court affirmed the City of Manila's right to implement
Ordinance No. 8027 as a lawful use of its police authority to further public
health, morals, peace, education, good order, safety, and welfare in
general. Because the legislation solely limits the oil corporations' use of the
land and does not constitute a compensable take, the court determined that
it is not unfair, oppressive, or confiscatory and does not violate their
property rights. The Court also stressed the importance of local autonomy
and the authority that local governments have to pass laws that benefit
their citizens as a whole. Since the ordinance was based on a fair
classification and applied uniformly to all firms and industries in the affected
area, the Court rejected the allegation that it was discriminatory.
Spouses Latip v. Chua, G.R. No. 177809, October 16, 2009.

Facts:
The Spouses Latip are held accountable for any unpaid rentals on the
rented cubicles after the Supreme Court overturns the Court of Appeals'
(CA) ruling. The Spouses Latip were forced to leave the rented property
Laila C. Lasam

and pay rent arrearages, monthly rentals, legal fees, and litigation costs
after the MeTC ruling found in favor of the respondent, Rosalie Chua.
Rosalie Chua is the owner of the Roferxane Building, a commercial
property in Parañaque City, according to the information provided by the
MeTC. On July 6, 2001, Rosalie filed a complaint against the Spouses
Latip for wrongful detainer plus damages. A lease agreement for two
cubicles in the Roferxane Building, signed by the Spouses Latip as the
lessees and Rosalie as the lessor, was one of the documents presented in
the complaint. The lease agreement lays out all of the terms and
circumstances of the rental, such as the monthly payment, arrears
payment, utility obligation, no subletting or change, and termination
provisions.
The lease is for a term of six years, beginning in December 1999 and
ending in December 2005. Rosalie's signed receipts attested to the
Spouses Latip's allegation that they had already paid the full P2,570,000.00
lease. Rosalie threatened to evict the Spouses Latip if they did not pay the
back rent in a demand letter she sent them. Rosalie's assertions were
refuted by the Spouses Latip, who contended that the P2,570,000.00
payment covered the entire lease amount. The MeTC decided in Rosalie's
favor, directing the Latip couple to leave the property and pay arrearages
on their rent, monthly rentals, legal fees, and litigation costs. The MeTC
finding was overturned by the RTC, which dismissed Rosalie's allegations
and ruled in favor of the Latip spouses. The RTC determined that the lease
was deficient in key components, including notarization and precise dates
for the duration of the agreement, and that it was therefore incomplete. The
RTC accepted the Spouses Latip's argument that the entire lease sum had
already been paid and that the lease had been amended and augmented
by their purchase of lease rights. The CA ruled that the leasing agreement
was genuine and full and that the P2,570,000.00 payment was goodwill
money, overturning the RTC decision and reinstating the MeTC decision.
The property is located in the Baclaran area, and the CA took judicial notice
of the alleged practice of giving goodwill money there. Based on the terms
of the lease and the receipts for the P2,570,000.00 payment, the CA
concluded that the Spouses Latip should be removed from the rented
cubicles.

The CA ruling was challenged to the Supreme Court by the Spouses

Latip. After considering the facts, the Supreme Court determined that the
Laila C. Lasam

lease was genuine and comprehensive and that the P2,570,000.00

payment represented advance rentals. After deducting P2,570,000.00 that
had already been paid in advance fees, the Supreme Court found the
Spouses Latip to be responsible for overdue rentals. The Spouses Latip
were compelled by the Supreme Court to reimburse Rosalie Chua for the
outstanding rent. The petition of the Spouses Latip was approved by the
Supreme Court, which overturned the CA ruling.
Issue:
Whether the Spouses Latip should be ejected from the leased
cubicles.
Ruling:
The purported practice of giving goodwill money to the lessor in the
Baclaran area was brought to the attention of the Court of Appeals (CA).
The Supreme Court disapproved, ruling that Rosalie had not presented
enough proof to substantiate her allegation and that the claimed practice
did not meet the requirements of renown. The Supreme Court ruled that the
P2,570,000.00 in receipts and the leasing contract should be regarded as
upfront rentals for the rented cubicles. The amount was not shown by the
court to be goodwill money, despite the assertion that it was. Whilst the
Spouses Latip were held accountable for any overdue rent under the
contract, P2,570,000.00 should have been subtracted from their obligation.

G Holdings, Inc. v. National Mines and Allied Workers, G.R. No.

160236,
Facts:
The petitioner, "G" Holdings, Inc. (GHI), is a domestic corporation
whose principal line of business is the acquisition and storage of stock in
various businesses. On August 3, 1992, GHI registered with the Securities
and Exchange Commission. The sole representative for the rank-and-file
workers of Maricalum Mining Corporation (MMC) in negotiations was the
private respondent, National Mines and Allied Workers Union Local 103
(NAMAWU). On October 19, 1984, the Philippine National Bank (PNB) and
the Development Bank of the Philippines (DBP) created MMC as a result of
their foreclosure of the assets of Marinduque Mining and Industrial
Corporation. August 1985 marked the beginning of MMC's commercial
Laila C. Lasam

activities. Through a Purchase and Sale Agreement signed by GHI and

Asset Privatization Trust (APT), GHI acquired 90% of MMC's shares and
financial claims on October 2, 1992. The money claims were transformed
into three P500M Promissory Notes that MMC issued in GHI's favor, each
of which was backed by mortgages on MMC's real estate. MMC and
NAMAWU got into a labor disagreement, and NAMAWU eventually filed a
notice of strike. NAMAWU won the labor conflict, and the execution of a
new collective bargaining agreement (CBA) was mandated. Once the
Purchase and Sale Agreement was signed and the required down payment
was fully paid, GHI gained physical possession of the mine site and its
infrastructure as well as complete control over the management and
operation of MMC.

The properties that the sheriff had levied were the subject of a Deed
of Real Estate and Chattel Mortgage completed by MMC in favor of GHI to
secure the promissory notes, according to a complaint filed by GHI with the
Regional Trial Court (RTC) to overturn the sheriff's levy. A writ of injunction
and a temporary restraining order (TRO) were issued by the trial court to
prevent the DOLE sheriffs from carrying out any further enforcement of the
writ of execution or holding a public sale of the assets that were levied. The
CA ruled that the foreclosure was irregular and that the mortgage between
MMC and GHI was a sham, setting aside the RTC issuances and ordering
the writ of execution to be executed immediately. GHI challenged the CA
ruling in an appeal to the Supreme Court, bringing up a number of points
such as the mortgage's legality and the breach of the corporate veil. The
Supreme Court upheld GHI's ownership claim to the contested assets by
acknowledging the mortgage's legitimacy and rejecting the piercing of the
corporate veil.

The real estate of the judgment debtor, CMI, which had been
mortgaged to a group of banks and then sold to Top Rate, was subject to
an attachment by the petitioner, a judgment creditor. Because the
properties had already been transferred to the group of banks, the sheriff's
levy on CMI's properties was really a levy on CMI's right to redeem the
assets from the mortgage. Regarding the question of whether GHI's
foreclosure on some of the contested properties occurred before or after
NAMAWU's levy, there is a factual disagreement. GHI's mortgage was
registered before NAMAWU levied any interest, giving it precedence over
creditors who obtained judgments later. Since the courts were already
aware of the mortgage's existence since 1992, its registration was not done
Laila C. Lasam

with the intention of defrauding NAMAWU. When the case came to pierce
the veil of corporate fiction, the CA ruled that the petitioner's justifiable
claims against MMC should take precedence over GHI's and MMC's
distinct corporate identities. A company has a separate and distinct
personality from its investors or other associated entities, according to
settled jurisprudence, but this independent identity can be ignored if it is
exploited to commit fraud or other crimes.

The discussions that resulted in the Purchase and Sale Agreement

between GHI and the government through APT were not a staged deal, nor
did they provide justification for breaching the corporate veil. According to
the theory of "piercing the veil of corporate fiction," the parent must have
total dominance and control over the subsidiary in order to utilize it against
the plaintiff in fraud or other wrongdoing. The two companies' distinct
corporate identities should not be breached due to the interlocking of
directors and executives between MMC and GHI. Based on a third party
claim of ownership over the levied properties, a regional trial court has the
authority to issue a writ of preliminary injunction and a temporary
restraining order to prevent the implementation of a labor tribunal's writ of
execution. A second action for ownership recovery or a complaint for
damages against the judgment creditor's bond may be initiated by the third-
party claimant. The preliminary injunction and restraining order were
granted by the lower court without a grave abuse of discretion because
they were based on both factual and legal grounds. Although the court
admitted NAMAWU's labor claims, they are still pending final execution and
may be entitled to additional remedies. The mortgage and foreclosure of
the assets that were up for foreclosure have been settled, and it has been
established that GHI and MMC are two independent, distinct entities. The
regional trial court's omnibus order is upheld, and the Court of Appeals'
ruling is reversed.

Issue:
Whether GHI has a valid ownership claim over the properties subject
to the labor dispute.
Ruling:
The GHI's legitimate ownership claim over the properties at issue in
the labor dispute was maintained by the court, which ruled in its favor. The
Laila C. Lasam

court upheld the legality of the mortgage between GHI and MMC and
dismissed the attempt to cut through the corporate fiction. The court
stressed that GHI had a legitimate ownership claim over the properties and
that the mortgage between GHI and MMC was genuine. The court
determined that GHI's mortgage foreclosure constituted a lawful use of its
rights as a mortgagee.
The court ruled that in this instance, the corporate fiction should not
be broken. The court observed that GHI has a right to defend its rights as a
mortgagee because the mortgage was executed prior to the start of the
labor dispute. The court further emphasized that GHI had a legitimate
alternative in foreclosing on the mortgage to recoup its obligation and that
this did not impede the fulfillment of the judgment award against MMC.

[ G.R. No. 221732. August 23, 2017 ]

FERNANDO U. JUAN, PETITIONER, V. ROBERTO U. JUAN
(SUBSTITUTED BY HIS SON JEFFREY C. JUAN) AND
LAUNDROMATIC CORPORATION, RESPONDENTS.
Facts:
Fernando U. Juan, the petitioner, won the case at the Supreme
Court, which emphasized that procedural issues shouldn't prevent the
disagreement from being resolved. In his laundry company, Juan stated
that he started using the name and mark "Lavandera Ko" on July 4, 1994.
1995 saw the opening of his washing business in Makati City, and on
March 17, 1997, he was granted a copyright certificate for the name and
mark.

In 1997, Laundromatic Corporation was established to manage the

laundry industry. On November 13, 1998, "Lavandera Ko" was registered
with the Department of Trade and Industry (DTI) as a business name. On
October 18, 2001, petitioner Fernando U. Juan registered "Lavandera Ko"
as a name and trademark with the Intellectual Property Office (IPO). After
learning of this registration, respondent Roberto claimed that petitioner
Fernando had been marketing his own franchises. Respondent Roberto
petitioned the RTC for an injunction, unfair competition, copyright
infringement, and the revocation of his name and trademark.
Laila C. Lasam

On June 10, 2004, the RTC issued a writ of preliminary injunction against
petitioner Fernando. After respondent Roberto passed away on July 21,
2008, his son Christian Juan took his place. On July 13, 2010, the RTC
finished the pre-trial conference. On September 23, 2013, the RTC issued
a resolution dismissing the petition. The RTC decided that since
"Lavandera Ko" was Santiago S. Suarez's original mark and creation,
neither party had the right to use it exclusively or appropriate it. The RTC
directed that Roberto U. Juan and Fernando U. Juan's registration
certificates be revoked.

Fernando, the petitioner, challenged the RTC's ruling to the CA. The
petitioner's noncompliance with Section 13 standards was the technical
reason the CA used to dismiss the appeal. Fernando, the petitioner,
submitted a certiorari review petition to the Supreme Court. The petitioner
brought up a number of points, such as the technical grounds for
dismissing the appeal, the difference between a copyright and a mark, and
his ownership of the mark "Lavandera Ko." Respondent Roberto contended
that the appeal ought to be rejected because it raised only legal issues and
the petitioner neglected to cite page references to the record. The petition
was approved by the Supreme Court, which overturned the CA's ruling.

The Supreme Court stressed that the court's main responsibility is to

administer justice and that procedural issues should not obstruct the case's
conclusion. The trade name "Lavandera Ko" was protected by a copyright,
and the Supreme Court determined that the RTC erred in holding that
neither party had the right to use it. Additionally, the Supreme Court
determined that the article that the RTC had used as support for copyright
protection was not a suitable topic for judicial notice. The case was
remanded by the Supreme Court to the RTC so that more processes may
be conducted to ascertain who is the legitimate proprietor of the trade
name "Lavandera Ko."

Issue:
Whether or not Fernando have ownership of the mark "Lavandera
Ko"?
Ruling:
Laila C. Lasam

The Supreme Court decided in Fernando's favor. Fernando was

entitled to use the trade name "Lavandera Ko" because trade name rules
protected it. In order to ascertain who has the superior right to use the trade
name, the matter was remanded to the RTC for additional proceedings.

Republic v. Science Park of the Philippines, Inc., G.R. No. 237714,

November 12, 2018
Facts:
The Republic of the Philippines is appealing the Court of Appeals' ruling to
approve Science Park of the Philippines, Inc.'s (SPPI) land registration
application. The Republic contends that since June 12, 1945, it and its
predecessors-in-interest have been in open, continuous, and exclusive
ownership of the land; SPPI was unable to demonstrate that the land is
disposable and alienable. In Malvar, Batangas, SPPI submitted an
application for the original registration of a 7,691-square-meter plot of land.
According to SPPI, the land was in open, continuous, exclusive, and well-
known possession and occupation by it and its predecessors-in-interest
since before June 12, 1945 and it was part of the alienable and disposable
territory of the public domain.
Along with certified copies of the appropriate DENR administrative order
and the land classification map, SPPI produced a certification from the
Department of Environment and Natural Resources (DENR) declaring that
the land is located inside the alienable and disposable zone. SPPI provided
documentary and oral proof demonstrating the ownership chain from
Gervacio Lat, the prior owner, to SPPI in order to bolster its claim of
possession.
However, the Republic contended that SPPI had not demonstrated that the
land is disposable and alienable and that it has been in the possession of it
and its predecessors-in-interest since June 12, 1945. The land is alienable
and disposable, and SPPI was able to prove that it has been in its
possession and occupation since before June 12, 1945, according to the
Municipal Circuit Trial Court (MCTC), which granted SPPI's application for
land registration.
Laila C. Lasam

Based on a provision in a prior land registration case involving SPPI, the

MCTC took judicial notice of the validity of the pertinent DENR
administrative order. The Republic filed an appeal with the Court of
Appeals, claiming that SPPI's application should not have been approved
by the MCTC. The land is disposable and alienable, and SPPI has
demonstrated that it has been in its possession and use since before June
12, 1945, according to the Court of Appeals, which upheld the MCTC's
finding. The Republic asked to have its request for reconsideration
dismissed. The Republic then petitioned the Supreme Court for review on
certiorari. According to the Supreme Court, SPPI was unable to provide
sufficient proof that it had owned and occupied the land since before June
12, 1945. The applicant for land registration bears the responsibility of
substantiating its purported possession and occupation of the land, as
highlighted by the Court. The Court determined that the testimonial
statements and tax declarations provided by SPPI were insufficient to
demonstrate the necessary length and kind of possession and occupation.
Issue:
Whether the Court of Appeals was correct in upholding the MCTC's
grant of SPPI's application for land registration.
Ruling:
The Republic's petition was approved by the Court, whereas SPPI's
request for land registration was turned down. It is the applicant's
responsibility to provide evidence of its purported possession and
occupation of the land in a land registration application. The applicant must
prove that the land is disposable and alienable, and that it has been openly,
continuously, exclusively, and notoriety-wise possessed and occupied since
June 12, 1945, or earlier, together with its predecessors-in-interest. SPPI
was unable to provide solid proof that it owned and occupied the land. The
type and length of the necessary possession and occupation could not be
established by the oral and documentary evidence that SPPI provided.

Trinidad y Bersamin v. People, G.R. No. 239957, February 18, 2019

Laila C. Lasam

Facts:
Jesus Trinidad y Bersamin was found guilty of illegal possession of
firearms and ammunition. Trinidad appealed the decision based on the
illegality of his arrest and subsequent search and seizure. An information
was filed against Trinidad on December 12, 2014, charging him with illegal
possession of firearms and ammunition. The prosecution alleged that on
November 14, 2014, Trinidad was arrested during a buy-bust operation
targeting a certain "Jessie" involved in illegal drug activities. During the
operation, a .38 caliber revolver loaded with six live ammunitions and a .22
caliber rifle loaded with seven live ammunitions were recovered from
Trinidad. Trinidad claimed that the firearms were pawned to him and that he
did not have any documentation for them.
Trinidad's counsel admitted that he had no license to possess or
carry firearms at the time of his arrest. Trinidad presented evidence of his
acquittal in the drugs cases arising from the same incident, arguing that it
should result in his acquittal in the illegal possession of firearms and
ammunition case as well. However, the trial court and the Court of Appeals
held that Trinidad's acquittal in the drugs cases was not relevant to the
illegal possession of firearms and ammunition case.
Issue:
Whether or not Trinidad's conviction for illegal possession of firearms
and ammunition should be upheld.
Ruling:
Trinidad was acquitted of the crime charged. The court held that the
evidence obtained from the unreasonable search and seizure was
inadmissible. The court found the arrest of Trinidad to be illegal as the
validity of the buy-bust operation could not be proven. Therefore, the
subsequent search on Trinidad was deemed unreasonable. All the
evidence seized during the unlawful arrest was deemed inadmissible. The
court took judicial notice of Trinidad's acquittal in the drugs cases, as the
circumstances of the buy-bust operation were closely interwoven and
interdependent with the present case. Since the firearms and ammunition
were recovered from the same unreasonable search and seizure, they
were also deemed inadmissible. Thus, Trinidad's acquittal was justified.
Laila C. Lasam