No Separate Crime of Illegal Possession of Firearms

If an unlicensed firearm is used in the commission of any crime, there can be no separate offense of simple illegal possession of firearms. Hence, if the “other crime” is murder or homicide, illegal possession of firearms becomes merely an aggravating circumstance, not a separate offense. (People vs. Ladjaalam, G.R. Nos. 136149-51, 19 September 2000, 340 SCRA 617)