Title
People vs. Fronda
Case
G.R. No. 130602
Decision Date
Mar 15, 2000
Three accused individuals are acquitted of selling and delivering marijuana due to the prosecution's failure to establish their identity beyond reasonable doubt, despite circumstantial evidence presented during the trial.
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Case Digest (G.R. No. 130602)

Facts:

  • The case involves Michael Fronda y Quindara, Antonino Flora y Sabado, Jr., and Lauro Millamina y Cinense, Jr.
  • They were charged with violating Section 4, Article II of Republic Act No. 6425 for allegedly selling and delivering marijuana.
  • The incident took place on October 8, 1996, in Baguio City, Philippines.
  • The prosecution's case hinged on a buy-bust operation by PO2 Ceasary Harry Bedey and PO3 June Corpuz.
  • A tip from a concerned citizen led PO2 Bedey to 341 A. Bonifacio Street, Baguio City.
  • Bedey claimed to have purchased a brick of marijuana from someone in a room occupied by the accused.
  • The accused were arrested and charged based on this transaction.
  • The prosecution's witnesses included PO2 Bedey, PO3 Corpuz, and Police Senior Inspector Alma Margarita Villaseñor, a forensic chemist.
  • The defense presented the accused and their landlady, Mrs. Lolita Flora, who testified that the accused were students and denied the allegations.
  • The trial court found the accused guilty and sentenced them to reclusion perpetua and a fine of P500,000.
  • The accused appealed, arguing that the prosecution did not prove their guilt beyond reasonable doubt.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that the prosecution failed to establish the identity of the offenders beyond reasonable doubt.
  2. The Court found that the trial court erred in convicting the accused based on circumstantial evidence....(Unlock)

Ratio:

  • The Supreme Court stressed that the identity of the offender must be proven beyond reasonable doubt in criminal prosecutions.
  • PO2 Bedey could not identify the persons involved due to the darkness at the scene.
  • PO3 Corpuz, who arrived after Bedey's signal, also failed to identify the individuals.
  • The Court noted that the trial court's finding that the accused were caught "flagrante delicto" lacked evidentiary support.
  • Being caught "...continue reading

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