Title
People vs. Comprado y Bronola
Case
G.R. No. 213225
Decision Date
Apr 4, 2018
Accused acquitted after Supreme Court ruled arrest and search illegal; seized marijuana inadmissible due to lack of probable cause and warrantless violation.

Case Digest (A.M. No. MTJ-05-1610)
Expanded Legal Reasoning Model

Facts:

  • Parties and Proceedings
  • The People of the Philippines charged Renante Comprado y Bronola with violation of Section 11, Article II, R.A. No. 9165 for possession of 3,200 g of marijuana.
  • RTC Branch 25, Misamis Oriental convicted him on April 18, 2013; the CA affirmed on May 19, 2014; appellant appealed to the Supreme Court (G.R. No. 213225).
  • Narrative of Events
  • On July 15, 2011, a confidential informant (CI) texted Police Insp. Dominador Orate Jr. that a marijuana courier and a female companion, carrying a black-violet “Lowe Alpine” backpack, would board Bus No. 2646 (KVP 988) from Bukidnon to Cagayan de Oro.
  • Police set up a checkpoint at Police Station 6, Puerto, Cagayan de Oro. At 11:00 PM, they flagged down the bus, boarded it, and found appellant, matching the CI’s description, with the said backpack containing a transparent cellophane of dried marijuana leaves.
  • Officers marked the bag “RCB-2” and its contents “RCB-1,” photographed them, and sent the specimen to PNP Crime Lab. Chemistry Report No. D-253-2011 confirmed marijuana weighing 3,200 g.
  • Appellant denied knowledge or ownership of the bag, claiming he carried it as a favor and that his initial arrest occurred in Bukidnon; he and his girlfriend were taken to Cagayan de Oro and subjected to custodial investigation without counsel.
  • Decisions Below
  • The RTC found the uncorroborated defense untenable, held mere possession consummates the crime, and sentenced appellant to life imprisonment plus ₱500,000 fine.
  • The CA affirmed, ruling appellant submitted to jurisdiction by failing to object pre-arraignment, treated the search under the moving-vehicle exception, and deemed inventory irregularities nonfatal to admissibility.

Issues:

  • Whether appellant’s warrantless arrest was valid.
  • Whether the seized items are admissible in evidence.
  • Whether appellant is guilty beyond reasonable doubt of illegal possession of marijuana.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.