Case Digest (G.R. No. 205228) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Paul Mark Malado y Balang and Warton Fred y Layogan (G.R. No. 243022, July 14, 2021), the First Division of the Supreme Court resolved an appeal by accused-appellant Warton Fred y Layogan (Warton), who was convicted alongside Paul Mark Malado y Balang (Paul) for illegal possession of marijuana bricks weighing 17,599 grams. On April 7, 2010 at around 9:00 p.m., a confidential informant (CI) tipped off the Philippine Drug Enforcement Agency–Cordillera Administrative Region (PDEA-CAR) that Paul and Warton would deliver marijuana near the entrance of the Strawberry Farm in Km. 6, La Trinidad, Benguet. A PDEA anti-narcotics team, led by Investigation Agent III Jeoffrey C. Tacio and comprising Agents Yapes, Asiong, Langwas and others, staked out the area. The CI identified Paul carrying a plastic bag of brick-shaped packages and Warton with a carton of similar packages. Agents immediately arrested Paul when he was about to flag a taxi, seized three tap Case Digest (G.R. No. 205228) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- The People of the Philippines charged Paul Mark Malado y Balang (minor) and Warton Fred y Layogan with illegal possession of 10 bricks of marijuana (total net weight 17,599 grams) on April 7, 2010 at Km. 6, Betag, La Trinidad, Benguet.
- The Regional Trial Court (RTC), Benguet Branch 9, rendered judgment on November 21, 2013 finding both guilty under Section 11, Article II of R.A. 9165, sentencing each to life imprisonment and a ₱500,000 fine.
- The Court of Appeals (CA) affirmed on September 8, 2017. Warton appealed to the Supreme Court, which rendered its decision on July 14, 2021.
- Seizure, Arrest and Documentary Records
- A civilian informant (CI) tip led PDEA-CAR agents (Yapes, Asiong, Langwas, Mangili, IA3 Tacio, Dir. Apalla) to stake out near the Strawberry Farm gate at around 8:30 p.m.
- At 9:00 p.m., the CI identified two men as Paul (carrying a blue-white striped plastic bag) and Warton (carrying a carton). Agents Yapes and Asiong confronted Paul, opened his bag, detected marijuana, marked and seized 3 bricks (“MWY-1” to “MWY-3”).
- Warton fled, dropping a carton. Agents Langwas, Mangili and IA3 Tacio chased and arrested him; Agent Yapes marked and seized 7 bricks inside (“MWY-4” to “MWY-10”).
- At PDEA-CAR office (around 1:00 a.m. April 8, 2010), in the presence of barangay, media and DOJ representatives, the team prepared the Joint Affidavit of Arrest, Booking Sheets, Inventory of Seized Items, and Request for Laboratory Examination; evidence was placed in PDEA evidence room.
- Laboratory Examination and Trial
- At PNP Crime Laboratory, PSI Biadang Jr. weighed the 10 bricks (net 17,599 g), conducted physical, chemical and confirmatory tests—positive for marijuana—and issued Chemistry Report No. D-18-2010. He sealed and turned over specimens to the PNP custodian.
- In court, PSI Biadang Jr. identified the marked items; the defense presented no witnesses. Accused waived presentation of evidence but filed a Joint Memorandum claiming illegal warrantless search, invalid arrest, and non-compliance with Section 21, Article II of R.A. 9165 (no photographs).
Issues:
- Whether Warton’s warrantless arrest was valid.
- Whether the subsequent warrantless search and seizure were reasonable.
- Whether Section 21, Article II of R.A. 9165 (chain of custody and photographing/inventory) was complied with.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)