Case Digest (G.R. No. 229071) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Eanna O’Cochlain, G.R. No. 229071, decided on November 25, 2019 under the 1987 Constitution, the accused-appellant Eanna O’Cochlain, a 53-year-old Irish national residing in Badoc, Ilocos Norte, was charged before the Regional Trial Court (RTC) of Laoag City (Branch 13) under Criminal Case No. 15585-13 with the illegal possession of two rolled sticks of dried marijuana leaves weighing an aggregate of 0.3824 grams in violation of Section 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). During routine airport security screening at the Laoag City International Airport on July 14, 2013, Security Screening Officer (SSO) Dexter Suguitan, relying on information from a Civil Aviation Authority of the Philippines security officer, conducted a pat-down search on O’Cochlain, who voluntarily consented by raising his arms. From two packs of Marlboro Red cigarettes in his pockets, Suguitan retrieved one pack containing two r Case Digest (G.R. No. 229071) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- Accused‐appellant Eanna O’Cochlain, a 53-year-old Irish national married to a Filipina, residing in Barangay Aring, Badoc, Ilocos Norte.
- Charged by Information dated July 15, 2013 in RTC, Branch 13, Laoag City (Crim. Case No. 15585-13), with illegal possession of two (2) sticks of dried marijuana leaves (0.3824 g), in violation of Sec. 11, Art. II, RA 9165.
- Circumstances of Arrest and Seizure
- On July 14, 2013 (~6:35–7:00 p.m.) at the Laoag City Int’l Airport, CAAP CSI Tamayo reported a marijuana odor and saw a Caucasian male “smoking.”
- SSO Suguitan frisked Eanna at the final security checkpoint with his consent; he produced two Marlboro packs—one contained two rolled sticks of dried leaves.
- Suguitan displayed the pack to PO1 Manadao Jr. and other personnel; he then handed it to PO3 Javier, who, accompanied by barangay officials and an ABS-CBN cameraman, inventoried and marked the sticks “EO-1” and “EO-2,” photographed them, and bagged them in a Ziploc.
- Eanna underwent medico-legal exam; specimens were submitted to Ilocos Norte Crime Lab; P/Insp. Navarro’s qualitative test was positive for marijuana.
- Defense Version
- Eanna alleged he smoked hand-rolled flavored tobacco outside the initial screening; the two rolled sticks were merely tobacco.
- He claimed the sticks shown at the station differed in size and wrapping, suggesting evidence switching.
- Proceedings Below
- RTC (Nov. 22, 2013) convicted Eanna: 12 years + 1 day to 14 years imprisonment and ₱300,000 fine; held the frisk valid as routine airport security and by consent; found chain of custody intact.
- CA (Feb. 9, 2016 Decision; July 21, 2016 Res.) affirmed; denied reconsideration.
- Eanna elevated the case to the Supreme Court.
Issues:
- Was the warrantless frisk and seizure of the rolled sticks valid under routine airport security procedures and the consent exception?
- Was there probable cause or reasonable ground to believe Eanna possessed marijuana at the time of frisk?
- Did the prosecution substantially comply with the chain of custody rule (Sec. 21, RA 9165) to preserve integrity and admit the seized items?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)