G.R. No. L-19147-8 - Albino Nicolas, et al. vs. The Director of Lands, Guillermo Camungao

Petitioner Alain Manalili y Dizon was charged under R.A. No. 6425, Sec. 8, Art. II, for possession of crushed marijuana residue on April 11, 1988.
The RTC of Caloocan City convicted him on May 19, 1989, sentencing him to 6 years & 1 day imprisonment and a ₱6,000 fine. The CA affirmed on April 19, 1993; reconsideration was denied January 20, 1994.

At around 2:10 PM on April 11, 1988, Anti-Narcotics policemen conducted surveillance near Caloocan City Cemetery based on intel of drug users in the area.
They observed a male with red eyes and a swaying gait; upon approach and request to see what he held, the man gave his wallet, inside which crushed marijuana residue was found.
The residue was turned over to the NBI Forensic Chemistry Section, tested positive for marijuana, and properly documented (Exhs. E-3, E-4, F, G).

Petitioner was allegedly on a tricycle when stopped, then physically searched—first on the street, then at the police station—in presence of bystanders; no contraband was found on his person.
He claims the police later planted marijuana in his pants to extort money; witnesses (tricycle driver, neighbor) corroborated that no drugs were discovered during the searches.

Whether the warrantless stop-and-frisk and seizure of the marijuana was lawful.
Whether the testimonies of the arresting officers contained material inconsistencies affecting credibility.
Whether the prosecution proved petitioner’s guilt beyond reasonable doubt.
Whether the defense of framing/extortion was sufficiently established.