Title
People vs. Gatong-o
Case
G.R. No. 78698
Decision Date
Dec 29, 1988
Court upholds convictions for marijuana sales, affirming entrapment as a legitimate law enforcement tactic.
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Case Digest (G.R. No. 78698)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against defendants-appellants Yabes Gatong-o, Emilio Tayan, and Bert Bacbac.
  • On May 30, 1984, in Angeles City, Pat. Celestino de la Cruz of the Narcotics Unit received a tip from a civilian informer about three Igorots planning to sell twelve kilograms of marijuana.
  • The informer visited the police station that night, prompting Captain Paras to order an entrapment operation.
  • At midnight, the informer contacted the police again, indicating the suspects were ready for a transaction.
  • The police arrived at Deang's Marketing & Commercial establishment around 12:30 AM on May 31, 1984.
  • Only Sgt. Raquidan exited the vehicle and was introduced to one of the suspects, Bert Bacbac.
  • After negotiations, Raquidan agreed to buy marijuana, and the suspects provided a plastic bag containing one kilogram of the drug.
  • Upon confirming the contents, Raquidan signaled for the arrest of the suspects.
  • A subsequent search of the suspects' hotel room yielded no additional incriminating evidence.
  • On June 14, 1984, an information was filed against the three defendants for violating the Dangerous Drugs Act of 1972.
  • The trial court found them guilty on April 3, 1987, sentencing each to reclusion perpetua and a fine of P30,000.
  • The defendants appealed, challenging the credibility of the prosecution's evidence and the circumstances of their arrest.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's decision, finding no error in crediting the prosecution's evidence.
  • The Court ruled that the entrapment operation was conducted lawfully and did not violate the defendants' rights.
  • The Court held t...(Unlock)

Ratio:

  • The Supreme Court distinguished between entrapment and instigation, clarifying that the criminal intent originated from the defendants, not the police.
  • The Court noted that the police acted on credible information and followed law enforcement pr...continue reading

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