Case Digest (G.R. No. 186635) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 2, 2006, in Dagupan City, Pangasinan, Police Officer 1 Bernard Azardon, PO1 Alejandro Dela Cruz, and SWAT team members, acting on a citizen’s tip of a “pot session,” entered the home of Rafael Gonzales y Cunanan without a warrant. They apprehended Gonzales along with Arnold Martinez y Angeles, Edgar Dizon y Ferrer, and Rezin Martinez y Carolino, and seized 115 empty plastic sachets, 11 rolled aluminum foils, and 49 cut aluminum foils bearing suspected shabu residue. A forensic examination by P/Insp. Lady Ellen Maranion confirmed methamphetamine hydrochloride in all sachets and several foils, and drug tests on the accused (except Orlando Doria) were positive for methamphetamine. The Regional Trial Court (Branch 41, Dagupan City) in Criminal Case No. 2006-0525-D convicted the four for violating Section 13 in relation to Section 11, Article II of Republic Act No. 9165, sentencing each to life imprisonment and a ₱500,000 fine. The Court of Appeals in CA-G.R. HC No. 0326 Case Digest (G.R. No. 186635) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- This is an appeal from the RTC’s February 13, 2008 Decision (Crim. Case No. 2006-0525-D, Branch 41, Dagupan City) convicting Arnold Martinez, Edgar Dizon, Rezin Martinez, and Rafael Gonzales of violating Sec. 13 in relation to Sec. 11, Art. II of R.A. 9165 (possession of dangerous drugs during parties or social gatherings).
- The Court of Appeals (CA) affirmed on August 7, 2009. The accused then appealed to the Supreme Court.
- Incident and Apprehension
- On September 2, 2006 at about 12:45 PM, PO1 Bernard Azardon received an unrecorded tip from an unnamed “concerned citizen” that a pot session was ongoing at Rafael Gonzales’s house in Trinidad Subdivision, Dagupan City.
- Without a warrant or prior surveillance, PO1 Azardon, PO1 Alejandro Dela Cruz, and SWAT members entered the premises. They arrested Orlando Doria outside and found Gonzales, Arnold Martinez, Edgar Dizon, and Rezin Martinez inside a room with:
- Open plastic sachets containing shabu residues
- Rolled and cut aluminum foil with residues
- The officers seized these items and delivered them to P/Insp. Lady Ellen Maranion of the Pangasinan Provincial Police Crime Laboratory. Laboratory tests showed that all 115 plastic sachets, all 11 pieces of rolled foil, and 27 of 49 cut foil tested positive for methamphetamine hydrochloride. All accused tested positive for methamphetamine use except Doria.
- The defense claimed the four were merely looking for a person named “Apper” to repair a jeepney, were never in a pot session, and were arrested without valid cause.
Issues:
- Whether the warrantless arrest and search were lawful under the Constitution and Rule 113, Sec. 5 of the Rules of Criminal Procedure.
- Whether the seized items were admissible evidence despite non-compliance with Sec. 21, R.A. 9165 (physical inventory, photography, and required markings).
- Whether the chain of custody of the seized items was duly established under Sec. 21, R.A. 9165 and relevant DDB regulations.
- Whether the evidence presented was sufficient to prove guilt beyond reasonable doubt.
- Whether the proper statutory provisions of R.A. 9165 were applied in charging the accused.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)