Case Digest (G.R. No. 104223) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Medario Calantiao y Dimalanta, G.R. No. 203984 (June 18, 2014), the accused-appellant, Medario Calantiao, was charged with the illegal possession of dangerous drugs under Section 11, Article II of Republic Act No. 9165. On November 11, 2003, in Caloocan City, POs Nelson Mariano and Eduardo Ramirez responded to a shooting complaint lodged by Edwin Lojera. Upon reaching the scene, they encountered a white taxi from which two armed men fired shots and fled. In the ensuing foot chase, Calantiao was apprehended along 5th Avenue corner 8th Street. A black bag in his possession was opened and found to contain two bricks of dried marijuana fruiting tops weighing 997.9 grams; his companion was found with a .38 revolver. The items were marked, turned over to SPO3 Pablo Temena, and submitted to the PNP Crime Laboratory, where P/SInsp. Jesse Dela Rosa confirmed the specimens as marijuana. At the Regional Trial Court (RTC) of Caloocan City (Branch 127), Calant Case Digest (G.R. No. 104223) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Information
- On November 13, 2003, Medario Calantiao y Dimalanta was charged with violation of Section 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) before the RTC of Caloocan City.
- The Information alleged possession of two bricks of dried marijuana fruiting tops weighing 997.9 grams.
- Prosecution Evidence
- Complainant’s Report and Police Response
- At around 5:30 PM, Edwin Lojera reported a shooting incident to PO1 Nelson Mariano and PO3 Eduardo Ramirez, arising from a traffic dispute on EDSA, Balintawak.
- Officers proceeded to 5th Avenue corner 8th Street, Caloocan City, found a white taxi, and were fired upon by two suspects who then fled but were apprehended.
- Seizure of Drugs and Firearms
- From Calantiao, PO1 Mariano recovered a black bag containing two bricks of dried marijuana fruiting tops and a magazine of .38 stainless ammunitions.
- From Calantiao’s companion, PO3 Ramirez recovered a .38 revolver.
- Items were turned over to SPO3 Pablo Temena for investigation; PO1 Mariano marked the bricks with his initials “NMa.”
- Laboratory Examination and Testimony
- P/SINSP Jesse Dela Rosa of the PNP Crime Laboratory issued Physical Sciences Report No. D-1423-03, confirming the specimens as marijuana.
- Testimonies of PO1 Mariano, PO3 Ramirez, and taxi driver Crisendo Amansec corroborated the arrest and seizure.
- Documentary Evidence
- Request for Laboratory Examination (Nov. 12, 2003) and Referral Slip.
- Physical Sciences Report and photographs of both bricks.
- Joint and separate sworn statements of arresting officers and witness.
- Defense Evidence
- Frame-Up Allegation
- Calantiao described the incident as a traffic mishap escalated by a rude gesture, leading to police hostility.
- Claimed PO1 Mariano slapped companion, punched them, and planted marijuana to frame them.
- Challenge to Seizure and Custody
- Asserted illegal search absent plain-view exception.
- Alleged broken chain of custody and lack of proper inventory procedures.
- RTC Decision (July 23, 2009)
- Found accused guilty beyond reasonable doubt of illegal possession of dangerous drugs.
- Held search incident to lawful arrest valid; all elements of the offense proven.
- Sentence imposed: life imprisonment and a ₱500,000 fine.
- CA Decision (Jan. 17, 2012)
- Affirmed RTC ruling in toto.
- Held warrantless arrest and search valid; seizure lawful and incidental to arrest.
- Found chain of custody intact.
- SC Decision (June 18, 2014)
- Petition for acquittal denied; affirmed CA decision.
- Addressed arguments on search validity, plain-view doctrine, and chain of custody.
Issues:
- Whether the warrantless search and seizure of the black bag containing marijuana was lawful under search-incident-to-arrest principles and not subject to plain-view requirements.
- Whether the chain of custody of the seized marijuana was properly maintained in accordance with Section 21, Article II of RA 9165 and its IRR.
- Whether non-compliance with marking requirements renders the seized marijuana inadmissible.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)