Case Digest (G.R. No. 243375)
Facts:
- Luzviminda Llamado y Villana (petitioner) vs. People of the Philippines (respondent).
- Decision rendered by the Supreme Court on June 30, 2020.
- Two Informations filed against Llamado on July 5, 2011, in the RTC of Marikina City:
- Criminal Case No. 2011-3921-D-MK: Illegal possession of drug paraphernalia (Section 12, R.A. No. 9165).
- Criminal Case No. 2011-3922-D-MK: Illegal possession of dangerous drugs (Section 11, R.A. No. 9165).
- Prosecution based on reports from a confidential informant, leading to surveillance and a test-buy operation.
- Search warrant obtained for Llamado's residence at No. 56 Exequiel Street, Barangay Sto. Niño, Marikina City.
- Law enforcement discovered two sachets of methamphetamine hydrochloride (shabu) and drug paraphernalia during the search.
- Items were seized, inventoried, and marked in the presence of local officials.
- Llamado denied allegations, claiming the search warrant was invalid due to address discrepancies and absence of required witnesses during inventory.
- RTC found her guilty, leading to conviction and sentencing.
- Llamado appealed to the Court of Appeals, which affirmed the RTC's decision.
- Filed a petition for review on certiorari with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition and reversed the Court of Appeals' decision.
- Luzviminda Llamado y Villana was acquitted of all charges. ...(Unlock)
Ratio:
- Ruling based on the principle of reasonable doubt; prosecution must prove illegal possession beyond a reasonable doubt.
- Emphasized the necessity of a clear chain of custody for seized items in drug-related cases.
- Noted failure to comply with Section 21 of R.A. No. 9165 regarding the presence of required witnesses during the inventory of s...continue reading
Case Digest (G.R. No. 243375)
Facts:
The case involves Luzviminda Llamado y Villana (petitioner) against the People of the Philippines (respondent), with the decision rendered on June 30, 2020, by the Supreme Court of the Philippines. The events leading to the case began on July 5, 2011, when two separate Informations were filed against Llamado in the Regional Trial Court (RTC) of Marikina City, specifically in Criminal Case Nos. 2011-3921-D-MK and 2011-3922-D-MK. The first Information charged her with illegal possession of drug paraphernalia under Section 12 of Republic Act No. 9165, while the second charged her with illegal possession of dangerous drugs under Section 11 of the same law.
The prosecution's case was built on the premise that Llamado was involved in illegal drug activities, as reported by a confidential informant. Following surveillance and a test-buy operation, a search warrant was obtained, leading to a search of Llamado's residence at No. 56 Exequiel Street, Barangay Sto. Niño, Marikina City. During the search, law enforcement officers discovered two plastic sachets containing methamphetamine hydrochloride (shabu) and various paraphernalia used for drug consumption. The items were seized, inventoried, and marked in the presence of local officials.
Llamado, however, denied the allegations, claiming that the search was conducted without a valid warrant and that she was not present during the seizure of the items. She argued that the search warrant was invalid due to discrepan...