Illegal possession of firearms, ammunition (P.D. 1866)

In the case of People v. Deunida, the Court declared Lazaro v. People "no longer controlling in view of our decisions in People v. Tac-an [182 SCRA 601 (1991)], People v. Tiozon, [198 SCRA 368 (1991)], and People v. Caling [208 SCRA 821 (1992)]" and held that Illegal Possession of Firearms and Ammunition does not absorb the crime of homicide or murder under the Revised Penal Code and therefore does not bar the simultaneous or subsequent prosecution for the latter crime. It is true that in the later case of People v. Barros, this Court again ruled that a person who commits homicide or murder through the use of an illegally possessed firearm, is liable solely for the aggravated form of illegal possession of a firearm as defined in P.D. No. 1866, 1, par. 2. This decision, however, has since been overruled by the Court en banc in People v. Quijada in which it was held that one who kills another with the use of an unlicensed firearm is guilty of two separate offenses of (1) either homicide or murder under the Revised Penal Code and (2) aggravated illegal possession of firearm under P.D. No. 1866, 1, par. 2. [G.R. No. 108871. November 19, 1996]