Case Digest (G.R. No. 109376) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Medel Coronel y Santillan et al., the petitioners—Medel Coronel y Santillan, Ronaldo Permejo y Abarquez, Nestor Villafuerte y Sapin, and Joanne Olivarez y Ramos—were charged under Republic Act No. 9165 for visiting a drug den (Section 7[b]) and using methamphetamine hydrochloride (shabu) (Section 15). On May 19, 2010, a PDEA team executed Search Warrant No. 4680(10) at a building in Tramo Street, Pasay City, recovered drug paraphernalia and white crystalline substances, and had the petitioners arrested after they attempted to flee. Inventoried and photographed in the presence of barangay officials, a DOJ prosecutor, and media representatives, the seized items were subjected to laboratory examination and the petitioners tested positive for shabu. The Regional Trial Court (RTC), Branch 231 of Pasay City, found them guilty on both counts in its October 30, 2012 decision, imposing six months’ rehabilitation for Section 15 and twelve years and one day Case Digest (G.R. No. 109376) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Arrest
- On May 19, 2010, a PDEA team, with a duly issued search warrant, coordinated with PNP-Southern Police District to raid a building at No. 1734 F. Muñoz (Tramo) St., Pasay City. They announced the warrant, forced entry, and pursued suspects who attempted to flee through windows.
- Four petitioners—Medel Coronel y Santillan, Ronaldo Permejo y Abarquez, Nestor Villafuerte y Sapin, and Joanne Olivarez y Ramos—were apprehended and brought back to the premises, where the warrant was read to them again before full search and seizure.
- Seizure of Evidence
- The team seized transparent plastic sachets with white crystalline substance (“shabu”), aluminum foils, improvised pipes and scoops, lighters, trays with residue, and cash (₱580 bills, ₱165 coins).
- The items were inventoried, marked, and photographed in the presence of the accused, barangay officials, the Assistant City Prosecutor, and a media representative.
- Laboratory and Drug Tests
- The seized items (Exhibits “D,” “B,” “C”) were formally offered; Chemistry Report Nos. PDEA-DT010-148 to 153 identified the substance as methamphetamine hydrochloride.
- Petitioners underwent mandatory drug testing and all tested positive for methamphetamine.
- Defense Version
- Each petitioner denied knowing the others or the nature of the premises, claiming they were forcibly brought by men in PDEA shirts while merely passing by or looking for acquaintances.
- No petitioner was found in possession of drugs at the moment of arrest, nor was there testimony of actual in-den use.
- Prior Judgments
- RTC (Pasay City, Branch 231) convicted petitioners of violating Sections 7 and 15, Article II, RA 9165, imposing rehabilitation (6 months) and imprisonment (12–14 years) with fines.
- CA affirmed the RTC decision (Apr. 29, 2014). SC denied petition for review on certiorari (Jan. 11, 2016). Petitioners filed a motion for reconsideration.
Issues:
- Whether the prosecution established a continuous and unbroken chain of custody of the seized evidence.
- Whether the premises raided qualified as a “drug den” under RA 9165.
- Whether petitioners knowingly visited the premises as a drug den (Section 7, RA 9165).
- Whether convictions for drug use (Section 15, RA 9165) should stand.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)