Case Digest (G.R. No. 99050)
Case Digest (G.R. No. 99050)
Facts:
People of the Philippines v. Conway B. Omaweng, G.R. No. 99050, September 02, 1992, Supreme Court Third Division, Davide, Jr., J., writing for the Court.Accused-appellant Conway B. Omaweng was indicted for violating Section 4, Article II of Republic Act No. 6425 (the Dangerous Drugs Act of 1972, as amended) after a criminal complaint was filed with the Municipal Trial Court of Bontoc, Mountain Province on 12 September 1988. When the accused failed to file counter-affidavits despite an extension, the municipal court deemed him to have waived preliminary investigation and found probable cause to elevate the case.
On 14 November 1988 the Provincial Fiscal filed an Information (Criminal Case No. 713) charging the accused with transporting 1,014 kilos of processed marijuana in 41 plastic bags placed in a travelling bag inside his Ford Fiera. After the Provincial Fiscal denied his motion for reinvestigation, Omaweng pleaded not guilty at arraignment on 20 June 1989.
At trial the prosecution presented four witnesses, including the two PC constables who manned a checkpoint and the PC forensic chemist who tested the seized material. The accused did not testify and offered only portions of a Joint Clarificatory Sworn Statement by the arresting officers. The trial court found the accused guilty on 21 March 1991, sentencing him to life imprisonment and a fine of P25,000 and ordering confiscation and destruction of the drugs; the case was then appealed to the Supreme Court.
On appeal the accused raised three principal errors: (1) insufficiency of evidence to prove guilt beyond reasonable doubt, (2) the trial court's failure to give effect to the joint clarificatory sworn statement of the arresting officers which allegedly exonerated him, and (3) that the contraband was obtained in violation of his constitutional right against unreasonable searches and seizures and therefore was inadmissible. The Court reviewed the evidence and the trial court’s findings and resolved the appeal in the Supreme Court.
Issues:
- Was the evidence sufficient to convict the accused beyond reasonable doubt for transporting prohibited drugs under Section 4, Article II of R.A. No. 6425?
- Did the trial court err in disregarding the Joint Clarificatory Sworn Statement of the arresting officers that purportedly exonerated the accused?
- Was the search and seizure that produced the drugs a violation of the accused’s constitutional protection against unreasonable searches and seizures, rendering the evidence inadmissible?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)