Case Digest (G.R. No. 65674)
Case Digest (G.R. No. 65674)
Facts:
People of the Philippines v. Danilo B. Capulong, G.R. No. 65674, April 15, 1988, Supreme Court Third Division, Gutierrez, Jr., J., writing for the Court.
The plaintiff-appellee is the People of the Philippines; the defendant-appellant is Danilo B. Capulong. On October 14, 1982, members of the Constabulary Anti-Narcotics Unit (CANU)—Sgt. Lino Jarilla (team head), Sgt. Adjare Jasani and Patrolman Reynaldo Resurreccion—carried out a buy-bust operation in Barangay Santissima, Santa Cruz, Laguna to apprehend alleged marijuana pushers. The team used an informant, Larry Estacio, who purportedly approached Capulong and negotiated the purchase of six small transparent plastic bags of dried marijuana for P50.00. Estacio gave Capulong a marked P50 bill (serial No. JF 247521); after receipt of the marked money the CANU officers arrested Capulong. Bernardo Paynaganan, who was with Capulong, was also detained; a stick of marijuana was found on Paynaganan. The marked money was found on Capulong.
Capulong was brought to CANU headquarters in Calamba, investigated, and executed an extrajudicial confession. The seized bags were submitted to the Philippine Constabulary laboratory and tested positive for marijuana. An information was filed charging Capulong with violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act of 1972), alleging sale of six bags of marijuana.
At trial Capulong pleaded not guilty and presented a defense that he and Paynaganan were merely watching a basketball game; the informant, allegedly drunk, first left and later returned with the marijuana and was followed shortly thereafter by CANU officers who arrested them. Capulong further claimed he was maltreated and forced to sign the extrajudicial confession and alleged that investigators extorted money from him and his relatives; he also claimed the investigators appropriated some of his personal effects. The defense pointed out delays in filing the complaint and in forwarding the seized items for laboratory testing and criticized the prosecution’s failure to present the informant, Estacio, at trial.
The Regional Trial Court (RTC), Branch XXVI, Santa Cruz, Laguna, convicted Capulong of violating RA 6425, sentenced him to life imprisonment and imposed a P20,000 fine (with accessory penalties), and assessed costs. The RTC credited the testimony of the CANU officers and the laboratory results, rejected the defense version and the allegations of coercion and extortion, and found the non-presentation of Estacio not fatal because his testimony would have been merely corroborative.
Capulong appealed to the Supreme Court from the RTC decision.
Issues:
- Was the extrajudicial confession of Danilo B. Capulong admissible in evidence notwithstanding that it was made without the assistance of counsel and in the face of allegations of force, duress, and intimidation?
- Did the remaining admissible evidence sufficiently establish Capulong’s guilt beyond reasonable doubt despite the alleged coercion, alleged extortion by investigators, delays in procedure, and the non-presentation of the informant?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)