Case Digest (G.R. No. 76649-51)
Facts:
The case at hand is PEOPLE OF THE PHILIPPINES vs. MARIO JAYMALIN, decided on October 19, 1992, by the First Division of the Supreme Court of the Philippines, under G.R. No. 90452. The accused, Mario Jaymalin, a resident of Kiangan, Ifugao, was charged with violating the Dangerous Drugs Act (RA 6425) for having possession of marijuana with intent to sell. The incident occurred on the evening of October 20, 1983, in Barangay Pindongan, Kiangan. The prosecution's case stems from a buy-bust operation conducted by the Informed National Police (INP) in response to a report regarding the planned sale of marijuana.
On that evening, a team composed of various police officers was briefed before proceeding to St. Joseph School, where the alleged drug deal was set to take place. Undercover officers, Lt. Edgar Danao and Cpl. Herman Kimmayong, were instructed to act as buyers. Around 8:30 PM, Jaymalin approached the officers, confirming their identities as buyers. He then led them to the
Case Digest (G.R. No. 76649-51)
Facts:
- Background of the Operation
- On the evening of October 20, 1983, at Brgy. Pindongan in Kiangan, Ifugao, authorities received intelligence about a planned marijuana sale.
- The information stemmed from a civilian informer known as Max, which triggered the formulation of a buy-bust operation under the framework of the Dangerous Drugs Act.
- Organization and Deployment of Law Enforcement
- The INP Ifugao Command in Lagawe organized a team composed of:
- Lt. Pedro Dulnuan
- Lt. Edgar Danao
- Cpl. Herman Kimmayong
- Cpl. Daniel Kinakin
- Patrolmen Catanglan, Binuhe, and Talasig
- Pre-operation briefing was held at Kiangan Central School around 7:30 p.m.
- Tactical assignments:
- Two officers (Danao and Kimmayong) were tasked to pose as buyers.
- The remaining team members were assigned to provide backup and support.
- Execution of the Buy-Bust Operation
- Based on Max’s report, the agents anticipated that the marijuana dealer would meet with potential buyers at the St. Joseph School compound at about 9:00 p.m.
- Under cover, Danao and Kimmayong positioned themselves near the high school’s boys’ department within the compound.
- At approximately 8:30 p.m., an individual carrying an umbrella, later identified as Mario Jaymalin, approached the undercover agents.
- Encounter, Evidence, and Arrest
- Initial Contact:
- The man queried whether they were “Max” and then whether they were the contacted buyer.
- Eventually, he invited them into the St. Joseph School compound.
- Presentation of Evidence:
- The accused produced a box which contained marijuana, later identified by the agents as such.
- The substance was then inspected at the scene and subsequently confirmed as marijuana by Major Esteban and a laboratory examination by Captain Benjamin Rubio.
- The box bore markings "Champion" and "Magno," adding to the chain-of-evidence.
- Arrest and Subsequent Violence:
- As negotiations proceeded, Lt. Danao announced the arrest of the accused.
- During the arrest, Francisco Jaymalin, the younger brother of the accused and armed with a rifle, intervened:
- Francisco fired his gun immediately, striking Mario on the arm.
- Evidence Handling:
- The box and its contents were promptly transferred to the Ifugao INP headquarters for safekeeping.
- The chain-of-custody was maintained, ensuring that the evidence (consisting of approximately seven and a half kilos of marijuana arranged in eight bunches) was properly documented and analyzed.
- Defendant’s Version and Discrepancies
- Mario Jaymalin’s Testimony:
- The accused claimed that after arriving home in Kiangan and finding his daughter absent, he went to his parents’ house via a shortcut through the school compound.
- He stated that he encountered unknown persons inquiring about Francisco, his brother, and later became involved in a confusing encounter marked by shouted commands and rapid gunfire.
- He admitted sustaining an injury to his arm during the melee.
- Observed Discrepancies:
- His narrative failed to align with the coordinated operation and the established facts of the buy-bust.
- The timing, sequence, and his behavior during the incident (such as engaging with strangers about his brother’s location) were inconsistent with the typical conduct expected in such situations.
Issues:
- Evidentiary Discrepancies and Witness Credibility
- Inconsistencies in the testimonies of the prosecution witnesses, notably:
- Variations in the accounts regarding who prepared sketches of the crime scene.
- Diverging descriptions of the clothing worn by the undercover officers (“poseur-buyers”).
- Differences pertaining to the handling, source, and amount of the entrapment money.
- Conflicting identification and role assignment of the civilian informer, Max.
- Discrepancies concerning who alerted the Jaymalin brothers about the police presence.
- Chain-of-Custody and Evidence Integrity
- The appellant challenged whether the seized evidence, particularly the marijuana, had maintained an unbroken and properly documented chain-of-custody.
- The reliability of the evidence was brought into question based on alleged irregularities in its handling.
- Defendant’s Alternative Narrative
- The accused asserted that he was simply looking for his missing daughter when he inadvertently became involved with the police operation.
- His claim suggested that he was mistakenly picked up, and that his actions (such as engaging with strangers) did not comport with typical behavior, thereby casting doubt on his version.
- Appropriateness of the Imposed Sentence
- The accused argued that the trial court erred in imposing reclusion perpetua (or life imprisonment) with accessory penalties, contending that reclusion perpetua and life imprisonment are not interchangeable.
- The issue centered on whether the penalty should have been strictly life imprisonment plus a fine under the Dangerous Drugs Act.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)