BERSAMIN v.

PEOPLE
G.R. No. 239957 February 18, 2019

FACTS:

 The prosecution alleged that police officers conducted a buy-bust operation to

apprehend a certain Jessie Trinindad who, purportedly, was involved in illegal drug
activities.
 After the alleged sale had been consummated, Trinidad was arrested and recovered
from him a 0.38 caliber revolver loaded with 6 live ammunitions and a 0.22 caliber rifle
loaded with 7 live ammunition.
 Trinidad claimed that the subject firearms and ammunitions were merely pawned to him.
 An Information was filed before the RTC charging Trinidad with Illegal Possession of
Firearms and Ammunition.
 Trinidad claimed hat aside from the present case, he was also charged with the crime of
Illegal Sale and Possession of Dangerous Drugs, which arose from the same incident,
but he was acquitted therein for failure of the prosecution to prove that he was validly
arrested thru a legitimate buy-bust operation.
 Trinidad formally offered in evidence the said acquittal ruling, which was objected by the
public prosecutor for being immaterial and irrelevant to the present case.
 The RTC found Trinidad guilty of the crime charged.
 The CA affirmed the Decision of the RTC.

ISSUE:

Whether the trial court can take judicial notice of the circumstances of the drug case filed
against Trinidad in relation to the present case.

RULING:

YES. The Court is aware that the findings on the illegality of Trinidad's warrantless arrest in
the drugs cases are separate and distinct from the present illegal possession of firearms and
ammunition case. Nevertheless, the Court is not precluded from taking judicial notice of such
findings as evidence, and apply them altogether for the judicious resolution of the same
issue which was duly raised in this case.

The general rule is that the courts are not authorized to take judicial notice of the contents of
the records of other cases. However, this rule admits of exceptions, such as when the other
case has a close connection with the matter in controversy in the case at hand.

Here, the drugs cases and this case are so interwoven and interdependent of each other
since the drugs, as well as the subject firearms and ammunition, were illegally seized in a
singular instance. Hence, the Court may take judicial notice of the circumstances attendant
to the buy-bust operation as found by the court which resolved the drugs cases.