Case Digest (G.R. No. 232006) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In In re: The Writ of Habeas Corpus for Michael Labrador Abellana, petitioner Michael Labrador Abellana, detained at the New Bilibid Prisons in Muntinlupa City, sought a writ of habeas corpus under Rule 102 of the Rules of Court against Hon. Meinrado P. Paredes, Presiding Judge of Regional Trial Court (RTC) of Cebu City, Branch 13, the People of the Philippines, and Supt. Benjamin Delos Santos, Chief of the Bureau of Corrections. On May 26, 2008 at approximately 4:30 p.m., police executing a valid search warrant under RA 9165 discovered in petitioner’s possession 6.89 grams of a white crystalline substance (later confirmed to weigh 4.4562 grams by re-examination) and drug paraphernalia in his residence in Barangay Suba, Cebu City. He was charged with violations of Sections 11 and 12, Article II of RA 9165. Petitioner pleaded not guilty, moved unsuccessfully to quash the search warrant, obtained bail after re-weighing, and endured trial under his first counsel, Atty. Dario Rama, Case Digest (G.R. No. 232006) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Petitioner Michael Labrador Abellana, detained at New Bilibid Prisons, Muntinlupa City.
- Charged with:
- Violation of Section 11, Article II, RA 9165 (possession of 6.89 g “shabu”).
- Violation of Section 12, Article II, RA 9165 (possession of drug paraphernalia).
- Search, Seizure, and Evidence
- May 26, 2008 – RTC Branch 13, Cebu City issues search warrant; police identify themselves; in petitioner’s front-pocket found:
- One sealed plastic pack of crystalline substance (marked SW-MAB-01).
- Paraphernalia: scissors, lighters, improvised clip, tinfoil, burner, empty packs, funnel.
- Qualitative re-weighing reduces seized shabu to 4.4562 g.
- Trial Court Proceedings
- Plea of not guilty; Motion to Quash Search Warrant denied (Sept 15, 2006).
- Pre-trial; petitioner first represented by Atty. Dario Rama, Jr.; later by Atty. Raul Albura (Entry of Appearance Dec 3, 2008).
- Petitioner granted bail (April 4, 2008).
- Prosecution rests; petitioner’s demurrer to evidence denied.
- April 30, 2009 – case submitted for decision for failure of petitioner/counsel to appear at defense evidence hearing.
- July 29, 2009 – RTC promulgates May 11, 2009 Decision convicting petitioner:
- 12 years+1 day to 15 years imprisonment + ₱300,000 fine (Sec 11).
- 6 months+1 day to 4 years imprisonment + ₱10,000 fine (Sec 12).
- Post-Decision Motions and Appeals
- Aug 13, 2009 – Motion for New Trial/Reconsideration; denied Dec 28, 2009 for failure to appear at promulgation without justifiable cause (Rule 120, Sec 6).
- Feb 10, 2010 – petitioner arrested after fugitive status; Atty. Albura withdraws.
- Aug 16, 2010 – Petition for Relief from Judgment filed; denied (untimely, improper remedy).
- CA certiorari petition dismissed Feb 17, 2012; resolution became final Mar 16, 2012.
- June 20, 2017 – petitioner files petition for writ of habeas corpus before the Supreme Court alleging deprivation of due process and competent counsel.
Issues:
- Whether the writ of habeas corpus may be granted as a post-conviction remedy to assail a valid judgment.
- Whether petitioner was deprived of:
- His constitutional right to due process.
- His constitutional right to competent counsel.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)