Case Digest (G.R. No. 84450)
Facts:
People of the Philippines v. Gloria Umali y Amado and Suzeth Umali y Amado, G.R. No. 84450, February 04, 1991, the Supreme Court First Division, Medialdea, J., writing for the Court.
In Regional Trial Court, Branch 53, Lucena City (Criminal Case No. 85-473), Gloria Umali and Suzeth Umali were charged with violation of Section 4 of the Dangerous Drugs Act of 1972 (as reflected in the information) for allegedly conspiring to sell marijuana to one Francisco Manalo on or about April 22, 1985. Upon arraignment Gloria pleaded not guilty; Suzeth remained at large. After trial the RTC rendered judgment on September 9, 1987, finding Gloria guilty beyond reasonable doubt and sentencing her to reclusion perpetua; proceedings against Suzeth were ordered archived pending her arrest and the warrant against her reiterated.
The factual background recounted by the trial court began with the April 27, 1985 investigation of a minor, Pierre Pangan, by Pat. Felino Noguerra for drug dependency and related offenses. The police learned that Pangan’s marijuana reportedly came from sources in the municipality; they enlisted detained suspect Francisco Manalo (then facing separate charges, including Criminal Case No. 85-516) to assist in identifying the supplier. With Manalo’s consent, police gave him four marked P5.00 bills to purchase marijuana and instructed him to return the contraband to police. Minutes later Manalo returned with two foils of dried marijuana which he said he bought from Gloria. Manalo executed a written statement; based on it the police secured a search warrant for Gloria’s residence.
Police served the warrant on April 22, 1985 (police blotter/return reflected the raid) and allegedly recovered from Gloria the four marked P5.00 bills and, from the kitchen, a can containing sixteen aluminum foils of dried marijuana; the search was conducted in the presence of Barangay Captain Punzalan and other witnesses. Samples were sent to the PC Crime Laboratory; Capt. Rosalinda Royales testified and identified the specimen as marijuana (Exhibit G). Separately, Manalo had been charged and convicted in Criminal Case No. 85-516 for possession of Indian hemp on April 5, 1985.
On appeal to the Supreme Court, appellant Gloria argued (1) that Manalo was an unreliable, biased witness whose testimony should not be credited; (2) that the marked money and marijuana were obtained in violation of her constitutional right against illegal search and seizure, making the evidence inadmissible; and (3) that the prosecution failed to establish the essential elements of sale/delivery beyond reasonable doubt and that the conviction rested on conjecture. The Solicitor General countered that Manalo’s criminality did not disqualify him as a witness and that his testimony was corroborated by police testimony and physica...(Subscriber-Only)
Issues:
- Was witness Francisco Manalo disqualified or so tainted by his pending criminal charges that the trial court erred in crediting his testimony?
- Were the marked peso bills and drug specimens inadmissible because they were the product of an illegal search and seizure?
- Did the prosecution prove beyond reasonable doubt the essential elements of selling/delivering marijuana so as to sustain conviction and avoid reliance on ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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