Case Digest (G.R. No. L-7667) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Allan Quijano y Sanding, G.R. No. 247558 (February 19, 2020), the accused-appellant, Allan Quijano, a detainee at the Manila City Jail, was charged by Information dated May 11, 2016 with violation of Section 11, Article II of Republic Act No. 9165, as amended by RA 10640, for allegedly possessing 735.8 grams of methamphetamine hydrochloride (“shabu”). On April 28, 2016 at about 1:20 p.m., Jail Officer JO2 Arthur Briones observed a visitor, Marivic Tulipat, receiving a light violet bag from within the jail bakery, which she then handed to Quijano. Suspicious, Briones called both individuals to him, opened the bag and found a blue inner bag containing a transparent plastic packet of white crystalline substance. Briones arrested Quijano and Tulipat, advised them of their rights, and caused marking, inventory, and photography of the seized items inside the jail in the presence of Tulipat, Quijano, Senior Assistant City Prosecutor Maria Josefina Conce... Case Digest (G.R. No. L-7667) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Trial Court Proceedings
- Charge and Arraignment
- On May 11, 2016, an Information was filed charging Allan Quijano y Sanding with illegal possession of dangerous drugs (735.8 g of “shabu”) under Section 11, Article II of RA 9165.
- Appellant pleaded not guilty; at pre-trial, parties stipulated to jurisdiction, identity, and testimony of JO2 Magallanes.
- Prosecution Evidence
- JO2 Arthur Briones, jail officer, observed visitor Marivic Tulipat receive a light violet bag in Manila City Jail. He called Tulipat and appellant Quijano, who hesitated and attempted to pass the bag back. Briones seized it, found a transparent bag with white crystalline substance, and arrested both.
- The seized items were marked (bags “ACD/4/28/16”, “ACB-1/4-28-16”, “ACB-2/4-28-16”), inventoried, photographed in the presence of witnesses, and delivered to PDEA at 8:20 PM. Forensic Chemist Perez’s report (PDEA-DD016-092) confirmed 735.8 g net of methamphetamine hydrochloride.
- Prosecution introduced documentary and object evidence: laboratory request/receipt, exhibits B–K (plastic bags, chemistry report, chain of custody documents, inventory, photos, affidavits, incident report).
- Defense Evidence
- Appellant testified he was a detainee waiting for his wife’s visit when Tulipat handed him the bag. He denied knowledge of its contents, asserting he merely held it on Tulipat’s request.
- No documentary evidence was offered by the defense.
- Trial Court Decision
- On March 23, 2017, the RTC found appellant guilty beyond reasonable doubt, sentenced him to life imprisonment and a ₱500,000 fine (subsidiary imprisonment in case of insolvency), giving credence to Briones’ testimony and applying the stop-and-frisk doctrine inside the jail.
- Court of Appeals Proceedings
- Appellant’s Arguments
- Lack of animus possidendi: no conscious intent or knowledge of the bag’s contents.
- Broken chain of custody and unexplained variance in weight (gross vs. net).
- Prosecution’s Response
- Appellant’s conduct demonstrated knowledge; chain of custody was complete; weight variance due to different scales and sample extraction.
- CA Decision (Dec. 10, 2018)
- Affirmed RTC decision, modified by deleting subsidiary imprisonment.
- Supreme Court Proceedings
- Appeal to the Supreme Court raising the sole issue of whether the CA erred in affirming appellant’s conviction.
- Both parties adopted their CA briefs; no supplemental briefs filed.
Issues:
- Whether the Court of Appeals erred in affirming appellant’s conviction for illegal possession of dangerous drugs.
- Subsidiary issues:
- Whether appellant had the requisite animus possidendi (intent to possess).
- Whether the chain of custody and integrity of the seized drugs—particularly the weight variance—were properly established.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)