Case Digest (G.R. No. L-10000)
Facts:
The People of the Philippines v. Carmen Lacson y Olves, G.R. No. 126174, August 29, 2000, the Supreme Court, Buena, J., writing for the Court. Accused-appellant Carmen Lacson y Olves was charged in two informations: (1) for unlawfully delivering and transporting 50 pieces of transparent plastic bags containing methamphetamine hydrochloride (shabu) on or about January 8, 1993 (Criminal Case No. 93-115148); and (2) for attempted corruption of a public official by offering Inspector Lucio Margallo IV P500,000 to secure her release while under arrest (Criminal Case No. 93-115149).A joint trial followed. The prosecution presented police officers SPO1 Cecilio Lopez and Insp. Lucio Margallo IV, and chemist Renee Eric Checa, whose laboratory report (Exhibit M, Lab Report No. C-16639) showed that the 50 specimens tested positive for methamphetamine hydrochloride, estimated at about five grams each (total ~250 grams). The police witnesses described a surveillance operation and an arrest at the foot of Nagtahan Bridge after an alleged handover of a shoe box containing tea bags of shabu. The prosecution adopted testimony introduced during bail proceedings as part of its evidence-in-chief.
The defense offered alibi and denial, with Carmen Lacson testifying she was arrested near her condominium after PACC-like agents blocked her vehicle, that her P500,000 was taken, and that she assisted police in locating another suspect under duress; her son, babysitter and other witnesses corroborated aspects of her account. The defense also challenged alleged irregularities in arrest, search, detention, handling of the seized items and custodial use of her cell phone.
The Regional Trial Court (RTC), Branch 45, Manila, rendered a joint Decision dated February 10, 1995: it convicted Lacson in Criminal Case No. 93-115148 (violation of Section 15, Article III in relation to specified subsections, Article I of Republic Act No. 6425, as amended) and...(Pro-only)
Issues:
- Did the trial court commit reversible error in accrediting the prosecution witnesses (police officers) and rejecting the accused’s alibi/denial and challenges to the arrest, search and detention?
- Was the imposition of subsidiary imprisonment in case of insolvency proper when the principal penalty...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)