Subject: Liberal Construction

People v. Walpan Ladjaalam

G.R. nos. 136149-51
September 19, 2000

Facts:
Appellant Walpan Ladjaalam also known as Warpan, was found guilty of three of the
four charges against him by the Regional Trial Court of Zamboanga City: a) for maintaining a
den for the use of regulated drugs; b) illegal possession of firearms; c) for multiple attempted
murder with direct assault; and d) for illegal possession of drugs.
In relation to the offense illegal possession of firearm, the Office of the Solicitor General
(OSG) contends that PD 1866 should be the applicable law as worded prior to its amendment by
RA 8294.

Issue:
Was the OSG correct in contending that PD 1866 should apply?

Ruling:
No. The Court held that, the simple reading 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, it becomes merely an aggravating circumstance. Since direct assault with multiple
attempted homicide was committed in this case, appellant can no longer be held liable for illegal
possession of firearms.
It is further stated that the penal laws are construed liberally in favour of the accused. In
the case at bar, the plain meaning of RA 8294 simple language is most favourable to appellant.
Therefore, appellant is found guilty of two offenses: a) direct assault and multiple
attempted homicide with the use of a weapon; and b) maintaining a drug den.