Title
People vs. Rodriguez
Case
G.R. No. 144399
Decision Date
Mar 20, 2002
Defendants were convicted of drug offenses due to credible police testimonies from a buy-bust operation, refuting their framing claims.
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Case Digest (G.R. No. 144399)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against accused-appellants Danilo D. Rodriguez and Edwin D. Rodriguez.
  • Events occurred on January 22, 1998, in Iloilo City, Philippines.
  • The accused were charged with violating Article II, Section 4, in relation to Article IV, Section 21(b) of Republic Act No. 6425, known as the Dangerous Drugs Act.
  • Charges were filed on January 26, 1998, alleging conspiracy to sell and distribute 932.3 grams of dried marijuana without a permit.
  • During the arraignment on April 15, 1998, both accused pleaded not guilty.
  • The prosecution presented three witnesses: P/SINSP Angela Baldevieso, PO1 Richard Lambino, and PO1 Wendel Alfonso.
  • A buy-bust operation was initiated after a confidential informant reported the accused's drug activities.
  • On January 21, 1998, PO1 Lambino arranged to buy marijuana from the accused.
  • The accused were apprehended the next day after delivering the marijuana.
  • The substance was tested and confirmed as marijuana.
  • The accused claimed they were framed and denied ownership, alleging coercion by police.
  • The Regional Trial Court found both guilty on January 25, 2000, sentencing them to reclusion perpetua and a fine of P3,000,000.00 each.
  • The accused appealed, arguing the trial court erred based on false testimony.

Issue:

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Ruling:

  • The Supreme Court affirmed the Regional Trial Court's decision, finding the accused guilty beyond reasonable doubt of violating the Dangerous Drugs Act.
  • The penalty of reclusion perpetua was upheld, but ...(Unlock)

Ratio:

  • The Court ruled that the sale of marijuana was consummated despite the non-payment of the full purchase price, as the law punishes the act of selling, distributing, and delivering prohibited drugs.
  • The acceptance of the offer and delivery of the drugs constituted a completed crime.
  • Testimonies from prosecution witnesses were consistent and credible, establishing the identity of the accused and the nature of the transaction.
  • The absence of the marked money d...continue reading

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