Title
Supreme Court
People vs. Lagmay y Alarcon
Case
G.R. No. 125310
Decision Date
Apr 21, 1999
Edgar Lagmay was acquitted of marijuana possession charges after the Supreme Court found insufficient evidence linking him to the bag, citing witness credibility issues and the prosecution's failure to prove guilt beyond reasonable doubt.

Case Digest (G.R. No. 111836)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves the People of the Philippines versus Edgar Lagmay y Alarcon for violation of Section 8, Republic Act No. 6425 (as amended).
    • The original decision by the Regional Trial Court (Davao City, Branch 17) sentenced the accused to death by electrocution, with a subsequent recommendation for clemency on account of the harshness of the penalty.
    • The decision was rendered in Criminal Case No. 34, 149-94, and later subjected to an automatic review by the Supreme Court.
  • Chronological Account of Events on June 7, 1994
    • Prior to the Incident
      • The accused, a Marine Engineering graduate, visited MATS College in Agdao, Davao City to obtain his SOLAS Certificate.
      • He left the school premises in the afternoon, traveled by pedicab to check on his father at the public market, and then journeyed by jeep from Toril to various points in the city.
    • The Jeep Ride and Checkpoint
      • At approximately 7:30 p.m., the accused boarded a jeep with several other passengers.
      • The jeep traversed Uyanguren (Ramon Magsaysay Avenue), passing through several streets and stops where passengers boarded and alighted.
      • During the ride toward Bankerohan, the accused fell asleep until a police checkpoint at Ulas awakened him.
      • At the checkpoint, a policeman repeatedly questioned him about a bag found beside his seat.
      • Despite the repeated inquiries and the officer’s aggressive posture—including cocking his weapon and issuing threats—the accused persistently denied ownership of the bag.
  • Detention and Interrogation
    • Arrest and initial detention occurred shortly after the incident when the accused was ordered to alight from the jeep and was subsequently frisked.
    • The bag in question was later found to contain 3,051.3 grams of dried marijuana leaves.
    • In subsequent procedures:
      • The police, including officers like SP03 Laput and Capt. Yu, subjected the accused to physical intimidation, coercion, and threats of further harm.
      • The accused was moved to the Ulas Police Sub-Station and later transferred to a detention facility known as the stockade in Catitipan.
      • Witnesses testified about the brutal interrogation methods, including repeated beating and threats, which left the accused visibly abused.
  • Presentation of Evidence and Testimonies
    • At trial, evidence relied heavily on testimony from:
      • Efren Sustiger, the jeep driver, who identified the accused as the person who had boarded the jeep carrying the bag.
      • The conductor, Hesorenan de la Cerna, who was in a better position to interact with passengers yet later expressed reluctance to testify because of threats.
      • Other passengers, such as Victor Degamo and Teresita Pecson, who eventually testified that they did not believe the accused was the owner of the bag, and that they were compelled by their conscience to come forward only after learning of the death sentence.
    • Significant inconsistencies were noted in the testimonies:
      • The driver’s account showed lapses regarding details such as the timing and distance from which he could observe the bag.
      • The conductor and passenger testimonies, though initially absent at the trial, emerged later suggesting a credible alternative explanation that another individual could have been the owner of the bag.
    • The trial court ultimately gave greater credence to the prosecution’s witnesses, particularly Sustiger, despite these noted inconsistencies.
  • The Trial Court’s Decision and Subsequent Motions
    • Based on the strength attributed to the prosecution’s evidence, the trial court found the guilt of the accused proven beyond reasonable doubt.
    • The accused’s motion for new trial, which sought to introduce newly discovered evidence and alternative testimonies, was denied.
    • The decision ordered the execution of the death penalty with an accompanying recommendation for clemency due to the personal circumstances of the accused.
  • Developments on Review by the Supreme Court
    • On automatic review, the Supreme Court undertook a careful examination of the entire record, including discrepancies in witness testimony and evidentiary lapses.
    • The Court highlighted:
      • The central role of the constitutional presumption of innocence and the requirement that guilt must be proven beyond a reasonable doubt.
      • The dangers of relying on inconsistent or coerced testimonies, particularly in a case that could result in the most severe penalty.
    • The evidence was found to be equally open to more than one explanation, with the possibility that another passenger was the true owner of the bag.

Issues:

  • Sufficiency of the Evidence
    • Whether the prosecution’s evidence was strong enough to establish the guilt of the accused beyond reasonable doubt.
    • Whether the inconsistencies in the testimonies, particularly those of the driver and the conductor, undermine the case against the accused.
  • Credibility and Motivations of Witnesses
    • The legitimacy of relying on testimony from witnesses who appeared only after the accused was sentenced, allegedly acting out of conscience.
    • Whether the delay in these testimonies and the external pressures (including threats by the police) should diminish their credibility.
  • Application of the Presumption of Innocence
    • How the constitutional presumption of innocence should affect the weighing of evidence provided by the prosecution.
    • Whether a reasonable doubt exists, considering the potential that someone else could have been the true owner of the bag.
  • Appropriateness of Capital Punishment
    • The inherent need to exercise caution in imposing the death penalty when evidence does not conclusively eliminate all scenarios consistent with innocence.
    • The impact of any error in judgment regarding evidence interpretation on a capital sentence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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