Case Digest (G.R. No. 129296) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Abe Valdez y Dela Cruz (G.R. No. 129296, September 25, 2000), appellant Abe Valdez was charged on September 26, 1996, in the Regional Trial Court (RTC) of Bayombong, Nueva Vizcaya, Branch 27, with unlawful cultivation of seven fully grown marijuana plants under Section 9 of the Dangerous Drugs Act of 1972, as amended. Based on an informer’s tip, a police reaction team led by Chief of Police Alejandro R. Parungao trekked to Sitio Bulan, Barangay Sawmill, Municipality of Villaverde at 5:00 a.m. on September 25, 1996. They found Valdez alone in his nipa hut, spotted seven five-foot-high flowering hemp plants about 25 meters away, asked him who planted them, and he allegedly admitted ownership. The officers uprooted the plants, photographed Valdez beside them, and sent a sample weighing 1.090 kg to the PNP Crime Laboratory, which positively identified it as marijuana. The Department of Environment and Natural Resources certified that the lot was publ Case Digest (G.R. No. 129296) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal charge and initial proceedings
- On September 26, 1996, an Information was filed charging Abe Valdez y Dela Cruz with violating Section 9 of R.A. No. 6425, as amended, for planting, cultivating and culturing seven fully grown marijuana plants (weighing a total of 2.194 kg) in Sitio Bulan, Brgy. Sawmill, Villaverde, Nueva Vizcaya.
- Appellant was arraigned on November 15, 1996, pleaded not guilty, and trial on the merits ensued.
- Prosecution evidence
- On September 24, 1996, SPO3 Marcelo Tipay received a tip from an informer regarding appellant’s marijuana plantation. Police Inspector Parungao formed a reaction team (Tipay, SPO2 Noel Libunao, SPO2 Pedro Morales, SPO1 Romulo Tobias, PO2 Alfelmer Balut) to “verify” the report and arrest the cultivator.
- At around 5:00 A.M. on September 25, the team, guided by the informer, trekked three hours uphill to appellant’s kaingin. They found seven five-foot flowering marijuana plants about 25 m from his nipa hut. PO2 Balut asked who owned them; appellant allegedly admitted ownership.
- The police uprooted and weighed the plants (2.194 kg), took photographs of appellant beside them, and arrested him. A 1.090 kg sample (Exh. “A”) was sent to the PNP Crime Laboratory in Bayombong.
- Forensic analyst Prevy Luwis conducted microscopic and chemical tests, confirming the specimen as marijuana. A DENR certification showed the land (Lot 3224, Timberland Block B, Integrated Social Forestry Area) was public domain, occupied by appellant without a Certificate of Stewardship.
- Defense evidence
- Appellant testified he was weeding his vegetable plot on September 25 when an unknown person led him to the site. He denied knowledge of the plants until police coerced him, with barangay peace officer Kiko Pascua threatening him.
- He claimed police forced him to admit ownership, pose for photographs, and uproot five plants. He noted ten other houses nearby, the closest 100 m away belonging to Carlito Pascua, uncle of Kiko Pascua.
- As rebuttal, SPO3 Tipay presented a sketch (undated, without a surveyor) showing the marijuana plot 40 m from appellant’s old hut and 250 m from Carlito Pascua’s hut.
- Trial court judgment
- The RTC of Bayombong found appellant guilty beyond reasonable doubt under Section 9 of the Dangerous Drugs Act and sentenced him to death by lethal injection.
- The RTC based its decision on the seized plants and appellant’s alleged admission of ownership.
Issues:
- Whether the search and seizure of the marijuana plants were lawful.
- Whether the seized plants were admissible in evidence.
- Whether the prosecution proved appellant’s guilt beyond reasonable doubt.
- Whether the death penalty imposed was proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)