Case Digest (G.R. No. 140546-47) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Modesto Tee, G.R. Nos. 140546-47, decided January 20, 2003, the accused-appellant, Modesto Tee a.k.a. Estoy Tee, a Chinese national businessman and resident of Baguio City, was charged with illegal possession of marijuana under Section 8, Article II of Republic Act No. 6425 as amended by R.A. 7659. On July 1, 1998, NBI and PNP-NARCOM operatives, acting on information supplied by a taxi driver–witness, Danilo Abratique, first conducted a warrantless search of a rented room at No. 27 Dr. Cariño St., Baguio City, seizing 336.93 kg of marijuana, which the trial court excluded as the fruit of an unreasonable search (Crim. Case No. 15822-R, resulting in acquittal). Later that evening, with Abratique as witness, NBI Special Agent Lising secured Search Warrant No. 415 (7-98) issued by RTC Judge Antonio Reyes to search Tee’s residence in Green Valley, Sto. Tomas, Baguio City, where 591.81 kg of marijuana in 26 boxes and one sack were found and seized. In C Case Digest (G.R. No. 140546-47) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Criminal Cases Nos. 15800-R and 15822-R before RTC Baguio City, Branch 6, for violations of Section 8, Article II, RA 6425 as amended by RA 7659.
- Appellant Modesto “Estoy” Tee charged with illegal possession of marijuana; first information alleged 928.74 kg total, later amended to two separate informations:
- Case No. 15800-R – 591.81 kg in 26 boxes + 1 sack.
- Case No. 15822-R – 336.93 kg in 13 sacks + 4 boxes.
- Arrest and Trial Proceedings
- On July 1, 1998, NBI and PNP NARCOM operatives, assisted by informant Danilo Abratique, conducted two searches:
- A warrantless entry at rented premises (336.93 kg) – ruled unconstitutional; evidence excluded.
- Search of appellant’s residence via valid search warrant (591.81 kg) – evidence admitted.
- Appellant moved to quash the warrant; motion denied. He refused to plead, so plea of not guilty was entered.
- Prosecution witness Abratique testified to helping transport and store marijuana, then tipping off NBI. NBI forensic tests confirmed the seized items were marijuana.
- Appellant’s defense: search warrant too general; testimony of Abratique hearsay; witness delays violated speedy-trial rights.
Issues:
- Validity of the search warrant for appellant’s residence.
- Prejudice to appellant’s rights due to:
- Delays and absences of prosecution witness Abratique.
- Trial court’s order reopening the case for Abratique’s testimony.
- Sufficiency of the prosecution’s evidence to prove illegal possession beyond reasonable doubt.
- Propriety of the penalty imposed (death sentence + ₱1 M fine).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)