STATUTORY CONSTRUCTION (Aids to Construction)

CASE: PEOPLE OF THE PHILS. V HON. JUDGE AMANTE PURISIMA

FACTS:
In the case of People of the Philippines vs Purisima, several defendants were
charged with “illegal possession of deadly weapon in violation of PD NO. 9.
The lower courts issued orders quashing or dismissing the charges against
those charged with illegal possession on the ground that petitioner failed to
allege facts that constituted the offense penalized under the said P.D. all the
information failed to state one element of the crime, that the defendant
carried a bladed, pointed or blunt weapon outside their residence in
furtherance or related to subversion, insurrection, or rebellion, organized
lawlessness or public disorder. The petitioner (government), in trying to
prevent the dismissal of the case argued that the law did not require that the
prohibited acts be related such activities and that the act prohibited was
essentially a malum prohibitum (refer to conduct that constitutes an
unlawful act only by virtue of statute as opposed to conduct that is evil in and
of itself or mala in se) penalized for reasons of public policy.
ISSUE:
Whether or not the charges against the defendants were punishable or a
violation of certain provision in Presidential Decree No. 9
HELD:
Guided by the principle that penal statutes are to be interpreted and applied
liberally in favor of the accuse, the Supreme Court ruled that the simple act
of carrying any of the weapons described in P.D. No. 9 was not a criminal
offense in itself, what made it a criminal act or punishable under the said P.D.
is the motivation behind it. The court explained that in the construction or
interpretation of a legislative measure, the primary rule is to look for the intent
and spirit of the law. Certain aids were available in ascertaining the intent for
P.D. No. 9 such as presence of events that led to its enactment as stated in
the “whereas” clause (whereas, these lawless elements having taken up
arms against our duly constituted government and against our people …and
whereas, it is evident that there is throughout the land a state of anarchy and
lawlessness, and chaos…). In addition, the court said that the results or
effects of the P.D. must be within the reason or intent, which in this case, it
is only the act of carrying blunt or bladed weapon with a motivation in the
desired result of Proclamation No. 1081(martial law-maintenance of law and
order) was within the intent of P.D. No. 9