Case Digest (G.R. No. L-47494) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Hedishi Suzuki, G.R. No. 120670, decided on October 23, 2003, the Regional Trial Court of Bacolod City, Branch 45, convicted the Japanese national Hedishi Suzuki of illegal possession of marijuana under Section 8, Article II of R.A. No. 6425, as amended, and sentenced him to death with a P10,000,000 fine. The Information alleged that on April 12, 1994, at Bacolod Airport, Suzuki unlawfully possessed approximately 1.9 kilograms of marijuana concealed in a box labeled “Bongbong’s piaya.” At trial, Philippine National Police officers from the Police Aviation Security Command (PASCOM) and the Narcotics Command (NARCOM) testified that routine airport security screening at the pre-departure area triggered a metal detector alarm when Suzuki and his box passed through. Upon refusal to open the box, Suzuki ultimately consented and fled when marijuana was discovered, but was apprehended nearby. Laboratory tests confirmed the presence of marijuana. Suzuki i Case Digest (G.R. No. L-47494) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Prosecution evidence
- November 1993: PNP Narcotics Command directs regional units to cover domestic airports; coordinates with PASCOM and local airport authorities.
- April 12, 1994: Appellant and a companion enter Bacolod Airport pre-departure area carrying a box marked “Bongbong’s piaya.” Metal detector alarmed; box taken to inspection table; appellant initially resists but consents to opening. Inside are eighteen foil-wrapped packs of dried fruiting tops. Weighed at 1.9 kg; appellant refused to sign confiscation receipt; specimens sent to PNP Crime Laboratory and tested positive for marijuana.
- Appellant arraigned, pleads not guilty, tried before the RTC, convicted of illegal possession of marijuana (>750 g) and sentenced to death plus a ₱10 million fine.
- Appellant’s defense
- Arrived from Osaka to collect a debt; stayed in Bacolod; received the box as a “pasalubong” from a woman stranger; claims ignorance of contents.
- At airport, misunderstood English instructions; learned of marijuana only after opening; denies intent to possess.
- Alleges frame-up by companion and police officers; refused to sign receipt; challenges validity of search, seizure, and arrest.
Issues:
- Search and seizure authority
- Did PASCOM/NARCOM have legal authority under RA 6235, LOI 399, and related MOUs to inspect appellant’s box?
- Was appellant’s consent to search voluntary and valid?
- Admissibility of evidence
- Does the seizure fall under constitutional exceptions (plain view, incident to arrest)?
- Was there probable cause to open the box and arrest appellant?
- Burden and sufficiency of proof
- Does possession of 1,900 g of marijuana give rise to a prima facie presumption of wrongful possession, placing burden on appellant to prove lawful license?
- Did appellant’s frame-up allegations and testimony create reasonable doubt?
- Penalty assessment
- Was the death penalty properly imposed under RA 6425, as amended?
- Was the ₱10 million fine within statutory limits?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)