Case Digest (G.R. No. 148547) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In this case, the petitioner, the People of the Philippines, sought to reverse a Decision promulgated on June 19, 2001, by the Court of Appeals, which upheld the Resolution and Order of Judge Marcial G. Empleo from the Regional Trial Court of Dipolog City, Branch 9. The controversy began on October 6, 1999, when a search warrant was executed at LS Lodge in Dipolog City, where private respondent Dante Mah y Cabilin was renting a room. The search yielded multiple illegal drugs, including thirty-two small and six big plastic sachets of suspected shabu (methamphetamine hydrochloride) and marijuana leaves. Following the search, Police Superintendent Virgilio T. Ranes filed two criminal complaints against Cabilin for violating Republic Act No. 6425 (the Dangerous Drugs Act), leading to the filing of two Informations by State Prosecutor Rodrigo T. Eguia before the Regional Trial Court. The first Information (Criminal Case No. 9272) charged Cabilin with possession of shabu, while the se... Case Digest (G.R. No. 148547) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Search and Seizure Operation
- On October 6, 1999, a search warrant was issued to search the room rented by private respondent Dante Mah at the LS Lodge, Dipolog City.
- During the search, police officers seized various items including:
- Thirty-two small plastic sachets containing white crystalline granules (shabu) weighing 2 grams;
- Six big plastic sachets containing white crystalline granules (shabu) weighing 4.4 grams;
- One roll/stick of dried Indian hemp (marijuana) leaves weighing 0.2 gram;
- One small plastic sachet containing white crystalline granules (shabu) weighing 0.05 grams.
- Filing of Criminal Complaints and Informations
- Following the search, Police Superintendent Virgilio T. Ranes filed two criminal complaints under Republic Act No. 6425 for:
- Violation of Section 16, Article III (illegal possession of shabu).
- Violation of Section 8, Article II (illegal possession of marijuana).
- State Prosecutor Rodrigo T. Eguia subsequently filed two separate Informations before the Regional Trial Court in Dipolog City:
- Criminal Case No. 9272 charging the possession of shabu totaling 6.4 grams.
- Criminal Case No. 9279 charging the possession of dried marijuana leaves.
- Arraignment and Motion to Dismiss
- On October 28, 1999, private respondent pleaded not guilty to both charges during arraignment.
- On February 17, 2000, private respondent filed a motion to dismiss Criminal Case No. 9279, arguing that:
- The single act of possessing drugs at the same time and place should not be bifurcated into two separate Informations.
- Since Criminal Case No. 9272 already covered the act, filing a second case amounted to splitting one cause of action.
- Trial Court Proceedings
- In its Resolution dated April 3, 2000, Judge Marcial G. Empleo directed the prosecutor to amend the filings and submit only a single Information, reasoning that:
- Both "shabu" and marijuana, although distinct in form, were seized at the same time and place, evidencing one single criminal act of possession.
- The splitting of one act into two separate cases was impermissible under the circumstances.
- The prosecution filed a motion for reconsideration, contending that separate violations of RA 6425’s provisions constituted distinct offenses; however, this motion was denied on May 2, 2000.
- Subsequent Developments and Suspension/Reinstatement of Proceedings
- The trial court suspended further proceedings in Criminal Case Nos. 9272 and 9279 pending the resolution of appeals.
- On April 27, 2004, the trial court dismissed both cases for unreasonable delay, but subsequently, on June 17, 2004, reinstated the cases upon the prosecution’s motion for reconsideration.
- Appeals and Certiorari Petition
- The prosecution’s challenge escalated as a petition for certiorari was filed with the Court of Appeals, which affirmed the trial court’s directive to file one single Information.
- The controversy reached the Supreme Court for final resolution on the proper charging in cases involving multiple drugs.
Issues:
- Whether the act of possessing both shabu and marijuana seized at the same time, on the same occasion, and at the same place constitutes one crime or two distinct offenses under RA 6425.
- Whether filing a single Information for two different kinds of drug violations conforms to the statutory scheme of the Dangerous Drugs Act, given that different penalties and quantity thresholds are prescribed for each drug.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)