Case Digest (G.R. No. 240447)
Facts:
People of the Philippines v. Jamal Rangaig y Ampuan, Saad Makairing y Lonto, and Michael Juguilon y Solis, G.R. No. 240447, April 28, 2021, Supreme Court Third Division, Leonen, J., writing for the Court.
The prosecution (plaintiff-appellee People of the Philippines) charged accused-appellants Jamal Rangaig y Ampuan (Rangaig), Saad Makairing y Lonto (Makairing), and Michael Juguilon y Solis (Juguilon) with violations of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002) in four Informations filed before the Regional Trial Court (RTC) of Dagupan City: Criminal Case Nos. 2011-0295-D to 2011-0298-D. The Informations alleged possession of minute quantities of methamphetamine hydrochloride (shabu), including possession during a social gathering (Art. II, Secs. 11 and 13 of RA 9165).
After arraignment the accused pleaded not guilty and the RTC conducted trial. The prosecution presented testimony of police officers, crime laboratory examiners, and civilian witnesses, and introduced marked physical evidence and chemistry reports indicating presence of methamphetamine hydrochloride. The accused each testified that they were surprised and forcibly taken from an unoccupied nipa hut after police entered following a tip, denied knowledge of the seized sachets, and described being restrained and photographed at the police station.
On June 22, 2016 the RTC (Branch 44, Dagupan City) rendered a Joint Decision convicting the three defendants on the charges and imposing varying penalties (including life imprisonment for the social-gathering count in Crim. Case No. 2011-0295-D and terms of years and fines for the other counts). The RTC ordered disposition of the seized sachets and paraphernalia in accordance with law.
The accused appealed to the Court of Appeals (CA). On January 15, 2018 the CA in CA‑G.R. CR‑HC No. 08489 affirmed the RTC’s Joint Decision in toto. The accused filed a Notice of Appeal (filed January 29, 2017; CA gave due course March 1, 2018) and the records were elevated to the Supreme Court. The Court required supplemen...(Pro-only)
Issues:
- Were the accused-appellants placed in double jeopardy by separate convictions under Section 11 and Section 13 of RA 9165?
- Were the warrantless arrests and consequent searches and seizures of the accused-appellants lawful?
- Was the chain of custody of the seized items ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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