Case Digest (G.R. No. 80544) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Binad Sy Chua, G.R. Nos. 136066-67, decided on February 4, 2003, the accused-appellant Binad Sy Chua was charged under two separate Informations in the Regional Trial Court of Angeles City, Branch 59. In Criminal Case No. 96-507, he was accused of unlawful possession of two large plastic bags containing approximately two kilograms of Methamphetamine Hydrochloride (shabu) and one small bag of about fifteen grams, in violation of Section 16, Article III of R.A. 6425 as amended by R.A. 7659. In Criminal Case No. 96-513, he faced a charge for illegal possession of twenty rounds of live .22-caliber ammunition without a license. The prosecution’s evidence stemmed from a police operation on September 21, 1996, at around 11:45 p.m., when officers acting on a tip from a confidential informant, who had reportedly followed Chua’s alleged drug distribution activities for two years, accosted him near the Thunder Inn Hotel in Balibago, Angeles City. During the Case Digest (G.R. No. 80544) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charges and Informations
- Criminal Case No. 96-507 – Accused-appellant Binad Sy Chua charged under Section 16, Article III of R.A. 6425, as amended by R.A. 7659, for possession of two (2) kilos and fifteen (15) grams of methamphetamine hydrochloride (shabu).
- Criminal Case No. 96-513 – Accused-appellant charged for possession of twenty (20) live .22-caliber ammunitions without license or permit.
- Prosecution Evidence
- Confidential informant tip – On September 21, 1996, informant reported that appellant would deliver drugs at Thunder Inn Hotel, Balibago, Angeles City. Police formed a surveillance team led by SPO2 Mario Nulud.
- Arrest and seizure – At about 11:45 PM, informant identified appellant arriving in a car carrying a sealed Zest-O juice box. Police accosted him; a small plastic bag with crystalline substance fell from his pocket. Body search yielded 20 live .22 bullets. Juice box opened, containing two large plastic bags of crystalline substance.
- Field and laboratory tests – Initial field test at PNP Headquarters identified “shabu.” Subsequent Crime Laboratory examination by S/Insp. Daisy Babor confirmed 1.942 kg and 13.815 g of methamphetamine hydrochloride.
- Defense Evidence
- Appellant’s version – Appellant claimed he was en route to Manila, stopped at a store, was accosted at gunpoint by police without warrant, and coerced into opening his car and carrying items.
- Corroboration – Security guard Wilfredo Lagman testified to witnessing appellant’s forced detention and the presence of armed policemen.
- Trial Court Decision (September 15, 1998)
- Criminal Case No. 96-513 – Acquitted for insufficiency of evidence (ammunitions).
- Criminal Case No. 96-507 – Convicted of illegal possession of shabu; sentenced to reclusion perpetua and fine of ₱1,000,000.
- Appeal to the Supreme Court
- Errors assigned – Lawfulness of warrantless arrest and search; admissibility and sufficiency of evidence to prove guilt beyond reasonable doubt.
- Appellant’s argument – Arrest and search violated constitutional rights; evidence is fruit of poisonous tree and should be excluded.
Issues:
- Whether the warrantless arrest and search of accused-appellant were lawful under any exception to the warrant requirement.
- Whether the seized drugs and ammunitions were admissible in evidence.
- Whether the remaining evidence proved appellant’s guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)