Facts:

• Carlito de Jesus, also known as "Carling," was convicted by the Regional Trial Court, Branch 124 in Caloocan City for violating the Dangerous Drugs Act of 1972.
• The violations pertained to Section 4 and Section 8 of Republic Act No. 6425.
• On January 17, 1984, de Jesus was arrested during an anti-narcotics operation in the Bisig Ng Nayon area, notorious for drug trafficking.
• He was caught selling five sticks of marijuana cigarettes to Police Officer Jesus Nadonga, who was acting as a poseur buyer for P10.00.
• A subsequent search revealed an additional 32 sticks of marijuana cigarettes in his possession.
• The marijuana was confirmed to be illegal by the National Bureau of Investigation's forensic chemistry unit.
• During the inquest, de Jesus admitted to the crime but later claimed he was coerced into signing a statement by the police, alleging police brutality.
• He did not report any injuries or seek medical assistance regarding the alleged abuse.
• The trial court sentenced him to life imprisonment and a fine of P30,000.00 for the sale of marijuana, and a 12-year sentence with a P12,000.00 fine for possession.
• De Jesus appealed the convictions, citing several errors.

Issue:

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Ruling:

• The Supreme Court ruled that the trial court erred in convicting de Jesus on two separate informations, as possession of marijuana is inherently included in the offense of selling it; thus, only one charge should have been filed.
• The Court affirmed the conviction for the sale of prohibited drugs, finding sufficient evidence to support the charge.
• The Court disreg...(Unlock)

Ratio:

• The Supreme Court emphasized that the legislature did not intend to impose separate penalties for possession when it is an inherent element of the sale of prohibited drugs.
• The Court noted that the severe penalties for selling drugs already reflect the seriousness of the offense, making ...continue reading