Case Digest (G.R. No. 258873) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Abdul Azis y Sampaco a.k.a. “Mohammad Macapundag Guimbor” @ “Major” and Alibair Macadato y Macadato @ “Ongkay,” the accused-appellants were charged in two Informations dated June 16, 2016 before the Regional Trial Court, Branch 127, Caloocan City, with violation of Section 11, Article II of Republic Act No. 9165 for illegal possession of dangerous drugs. On June 15, 2016, at around 5:00 p.m., police officers conducting “Oplan Galugad” in Phase 12, Barangay 188, Tala, Caloocan City, observed Azis and Macadato exchanging knot-tied and heat-sealed sachets containing suspected methamphetamine hydrochloride (“shabu”). PO1 Alcova, from a distance of 1.5 meters, heard Azis say “eto pa yung tamok galing kay Patak,” saw him hand over the plastic bag to Macadato, and then arrested them in flagrante delicto. From Azis’s sling bag, officers seized five sachets totaling 491.69 grams; from Macadato’s, six sachets totaling 131.09 grams. Marking was done at the a Case Digest (G.R. No. 258873) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charges and Informations
- Criminal Case No. C-97030 (People v. Abdul Azis y Sampaco a.k.a. “Major”)
- Date/Place: June 15, 2016, Caloocan City
- Offense: Unlawful possession of five knot-tied transparent plastic bags of methamphetamine hydrochloride (shabu) marked “AZIS/JA-1” to “AZIS/JA-5” with total net weight of 491.69 g, positive in laboratory test.
- Criminal Case No. C-97031 (People v. Alibair Macadato y Macadato a.k.a. “Ongkay”)
- Date/Place: June 15, 2016, Caloocan City
- Offense: Unlawful possession of six heat-sealed sachets of shabu marked “MACADATO/CDL-1” to “MACADATO/CDL-6” with total net weight of 131.09 g, positive in laboratory test.
- Arrest, Seizure, and Initial Procedures
- Oplan Galugad Operation
- Conducted by PO1 Jordan A. Alcova, PO1 Carlon Dave Lacson, and other operatives around 5 p.m. in Phase 12, Barangay 188, Tala.
- PO1 Alcova observed from 1.5 m away Azis saying “eto pa yung tamok galing kay Patak,” handing Macadato a plastic bag of suspected shabu, which Macadato slid into his sling bag.
- Apprehension and Marking of Evidence
- Both accused were arrested in flagrante delicto.
- PO1 Alcova marked Azis’s sling bag and five sachets; PO1 Lacson marked Macadato’s sling bag and six sachets.
- Inventory, Photography, and Laboratory Examination
- Place and Witnesses
- Fearing a mob at the scene, officers moved to the police station for inventory and photography.
- Only media representative Bernard Ariate attended; no elected official or DOJ representative responded (after office hours).
- Chain of Custody Continuation
- Investigator PO2 Jerome Pascual received the items, prepared inventory, and signed chain of custody forms.
- Items and laboratory request were personally delivered to Forensic Chemist Lourdeliza G. Cejes at NPD Crime Laboratory (Valenzuela Satellite).
- Cejes conducted qualitative tests: positive for methamphetamine hydrochloride; specimens sealed and deposited with Evidence Custodian.
- Defense Version
- Abdul Azis’s Testimony
- Claimed frame-up: police unlawfully raided his home at ~11 a.m., destroyed property, seized a black sling bag containing no drugs, then later presented Macadato at station.
- Witnesses for Macadato
- Imam Jamal M. Sharief: witnessed Macadato’s arrest at ~8 a.m. from 100 m away, did not know reason for arrest.
- Monacaya M. Macadato (sister): saw police raid near her travel agency, followed them to brother’s house, saw arrest, unaware of cause.
- Procedural History
- RTC, Branch 127, Caloocan City
- July 8, 2016: Motions to consolidate granted; accused pleaded not guilty.
- February 22, 2019: Trial court convicted both under RA 9165 Section 11; sentenced to life imprisonment and P 500,000 fine each; ordered drug forfeiture and destruction.
- Court of Appeals
- CA-G.R. CR-HC No. 12604: August 24, 2020 decision affirming RTC conviction.
- Supreme Court
- G.R. No. 258873: Petition for review denied; SC decision promulgated August 30, 2023.
Issues:
- Whether the warrantless arrests and searches were lawful.
- Whether the prosecution substantially complied with the chain of custody rule under RA 9165.
- Whether the evidence of illegal possession was admissible.
- Whether the defense of frame-up was sufficiently proven.
- Whether the volume and handling of seized drugs negate planting or tampering.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)