Case Digest (G.R. No. 238453)
Facts:
In People of the Philippines v. Jaime Sison, Leonardo Yanson, and Rosalie Bautista (G.R. No. 238453, July 31, 2019), the plaintiff-appellee, the People of the Philippines, charged Sitio M’lang, North Cotabato residents Jaime Sison (driver), Leonardo Yanson (passenger and accused-appellant), and Rosalie Bautista (passenger) with transporting six kilos of dried marijuana, in violation of Section 4 of Republic Act No. 6425. On May 31, 1996, at about 8:30 a.m., the M’lang Municipal Police received a radio tip that a silver‐gray Isuzu pickup bearing plate SDC 619 was transporting marijuana from Pikit. A checkpoint was set up along the Matalam–M’lang road, and around 9:30 a.m. the vehicle was flagged down. Although no search warrant was presented, officers compelled Sison to open the hood, where they found two sacks of suspected marijuana. The contraband and the three occupants were taken to the police station, and the next day the seized items were submitted to the Davao City Crime LCase Digest (G.R. No. 238453)
Facts:
- Tip and checkpoint operation
- On May 31, 1996 at about 8:30 a.m., the M’lang Municipal Police Station received a radio message reporting a silver-gray Isuzu pickup (Plate No. SDC 619) carrying three persons and transporting marijuana from Pikit.
- A police checkpoint was set up on the national highway between Matalam and M’lang. At around 9:30 a.m., officers stopped the pickup, asked the driver to open the hood, and found two sacks containing dried marijuana leaves.
- Seizure, examination, and identification
- The vehicle, driver (Jaime Sison), and two passengers (Rosalie Bautista and Leonardo Yanson) were brought to the M’lang police station; the seized sacks remained in custody.
- The following day, the sacks were delivered to the Davao City Crime Laboratory. Superintendent Mallorca tested and reported a total weight of 5,637 grams of marijuana.
- Trial court proceedings
- An Information for violation of Section 4, Republic Act No. 6425 (Dangerous Drugs Act of 1972) was filed before RTC Branch 16, Kabacan, Cotabato. All three accused pleaded not guilty.
- The prosecution presented six police witnesses; the defense presented the three accused as witnesses.
- On March 11, 2013, the RTC convicted all accused, sentencing each to life imprisonment and a ₱20,000 fine; it ordered the vehicle’s return to its owner.
- Appellate history
- The Court of Appeals, in its January 23, 2018 Decision, affirmed the RTC judgment with modification—imposing reclusion perpetua instead of life imprisonment.
- Leonardo Yanson alone appealed to the Supreme Court, raising issues on search validity, chain of custody under RA 9165, and conspiracy.
Issues:
- Whether the warrantless search and seizure of the pickup was valid.
- Whether Section 21 of RA 9165 (chain of custody) applies retroactively.
- Whether accused-appellant Leonardo Yanson conspired with co-accused in transporting marijuana.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)