Case Digest (G.R. No. 218402) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Ramil Galicia y Chavez, the appellant was charged under Republic Act No. 9165 for four distinct offenses arising from a police operation on February 10, 2006 in Pasig City. Acting on an anonymous tip, PNP officers secured Search Warrant No. 4271-06 to raid the Mapayapa Compound, which they subdivided into target areas. In Target No. 8 they found Ramil Galicia y Chavez inside a shanty with his pregnant wife. The arresting team, led by P/Insp. Ancieto Pertoza, SPO2 Roberto Agbalog and PO2 Roberto Beascan, seized eight sachets containing a total of 1.15 grams of methamphetamine hydrochloride (“shabu”), plastic lighters, aluminum foil tooters, weighing scales, scissors, and other paraphernalia. Galicia’s driver’s license and a personal photograph—indicative of his occupation of the shanty—were reportedly observed but not seized. He was Mirandized, arrested on the spot, and brought with the seized items to Camp Crame, after which the drugs were tested Case Digest (G.R. No. 218402) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charges against appellant
- Criminal Case No. 14821-D (Section 6, Article II, RA 9165): Maintenance of a drug den in a shanty at F. Soriano Street, Barangay Palatiw, Pasig City.
- Criminal Case No. 14822-D (Section 11, Article II, RA 9165): Illegal possession of eight sachets of methamphetamine hydrochloride (‘shabu’), totalling 1.15 grams.
- Criminal Case No. 14823-D (Section 15, Article II, RA 9165): Use of methamphetamine hydrochloride (‘shabu’).
- Criminal Case No. 14824-D (Section 12, Article II, RA 9165): Possession of paraphernalia (two digital scales, seven lighters, four aluminum foils, five improvised tooters, scissors).
- Investigation, arrest, and trial
- Undercover surveillance and test-buys
- An anonymous tip led media cameraman Arnel Tugade to conduct video surveillance in late January 2006.
- Police test-buys worth ₱300 and ₱100 confirmed sale of ‘shabu’; specimens tested positive in the PNP Crime Laboratory.
- Search warrant and raid
- On February 9, 2006, RTC Quezon City issued Search Warrant No. 4271-06 based on surveillance reports and video evidence.
- On February 10, 2006, over 200 PNP personnel, media, and DSWD representatives raided the Mapayapa Compound; appellant was arrested in Target No. 8.
- Seizure of items and testing
- Officers found plastic sachets, scales, lighters, aluminum foil, wallet with driver’s license, and a photograph in appellant’s shanty.
- Seized items were marked, inventoried, and submitted to the PNP Crime Laboratory, which confirmed presence of methamphetamine hydrochloride.
- A confirmatory urine test on appellant was positive for dangerous drugs.
- Trial court decisions
- RTC of Pasig (Dec. 19, 2007) convicted appellant of all four counts, imposing life imprisonment for maintenance of a den, varying terms for possession counts, and rehabilitation for drug use.
- CA (Mar. 22, 2013) affirmed the RTC decision.
Issues:
- Whether appellant is guilty beyond reasonable doubt of:
- Maintenance of a drug den (Section 6, RA 9165).
- Illegal possession of dangerous drugs (Section 11).
- Illegal possession of drug paraphernalia (Section 12).
- Use of dangerous drugs (Section 15).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)