Case Digest (G.R. No. L-13246)
Facts:
In Rodolfo Espano vs. Court of Appeals and People of the Philippines (G.R. No. 120431, April 1, 1998), petitioner Rodolfo Espano was charged by information dated July 14, 1991 before the Regional Trial Court of Manila, Branch 1, for violation of Article II, Section 8 of Republic Act No. 6425, as amended (the Dangerous Drugs Act). At around 12:30 a.m., Philippine National Police officers Romeo Pagilagan, Wilfredo Aquino, Simplicio Rivera, and Erlindo Lumboy conducted a buy-bust operation at the corner of Zamora and Pandacan Streets, Manila, upon reports of drug pushing. They observed Espano allegedly handing “something” to a customer. After the buyer departed, the officers identified themselves, frisked petitioner, and recovered two cellophane tea bags containing marijuana. Espano admitted there was more at his residence, leading to the seizure of ten additional identical bags. The specimens, totaling 5.5 grams, tested positive for marijuana by forensic chemist Annabelle Alip. EsCase Digest (G.R. No. L-13246)
Facts:
- Parties and Procedural Posture
- Accused-Petitioner Rodolfo Espano was charged under Republic Act No. 6425, as amended (Dangerous Drugs Act), for possession of twelve plastic cellophane bags containing 5.5 grams of marijuana on July 14, 1991, in Manila.
- The Regional Trial Court (RTC) of Manila, Branch 1, convicted him on August 14, 1992, sentencing him to 6 years and 1 day to 12 years imprisonment and a ₱6,000 fine; the Court of Appeals (CA) affirmed the conviction in CA-G.R. CR No. 13976 on January 16, 1995.
- Prosecution Evidence
- Patrolman Romeo Pagilagan and a buy-bust team observed Espano allegedly selling marijuana in Zamora and Pandacan Streets at about 12:30 a.m.; after the buyer left, they frisked him and seized two cellophane tea bags, then recovered ten more bags at his residence.
- Forensic Chemist Annabelle Alip tested the specimens and confirmed positive identification of marijuana, total weight 5.5 grams.
- Defense Evidence
- Espano testified that he was asleep at home when police, purportedly seeking his brother-in-law, handcuffed and brought him to the station; he denied knowledge of drugs.
- His wife, Myrna, corroborated that he was at home and that the police framed him.
- Lower Courts’ Decisions
- The RTC found the prosecution witnesses credible, rejected the alibi and frame-up defense as afterthoughts, and declared the marijuana forfeited to the government.
- The CA affirmed in toto the conviction, leading to this Supreme Court petition for review.
Issues:
- Whether the marijuana seized from petitioner's person and residence was admissible in evidence.
- Whether the presumption of innocence outweighs the presumption of regularity in police performance.
- Whether petitioner’s constitutional rights to confrontation and compulsory process were violated.
- Whether the prosecution’s evidence was improperly identified or irrelevant.
- Whether failure to present the informant creates reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)