Case Digest (G.R. No. 254208) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 21, 2015 at around 3:00 p.m., in Barangay Cadawinonan Housing Project, Dumaguete City, a Special Operations Group buy-bust team of the Negros Oriental Police Provincial Office, led by SPO4 Allen Jude Germodo and with Police Officer I Darelle Jed Delbo as poseur-buyer, arrested Ma. Del Pilar Rosario C. Casa a.k.a. “Marfy Calumpang,” “Madam,” and “Mah-mah” (accused-appellant) after she sold one heat-sealed sachet containing 0.13 g of methamphetamine hydrochloride (“shabu”) and possessed 11 sachets with an aggregate weight of 10.99 g of shabu. The sachets and money were marked, inventoried, and photographed at the SOG office in the presence of a DOJ representative, a media representative, and the barangay captain. A forensic chemist later confirmed the positive shabu results, and appellant’s urine test likewise showed methamphetamine. The Regional Trial Court, Branch 30 of Dumaguete City, on March 28, 2017 found her guilty beyond reasonable doubt of Illegal Sale (Section 5,...
Case Digest (G.R. No. 254208) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On July 21, 2015 in Dumaguete City, Ma. Del Pilar Rosario C. Casa a.k.a. “Marfy Calumpang” was charged in two Informations under RA 9165, as amended by RA 10640:
- Case No. 2015-23066—illegal sale of one (1) heat-sealed sachet containing 0.13 g of methamphetamine hydrochloride;
- Case No. 2015-23067—illegal possession of eleven (11) heat-sealed sachets totaling 10.99 g of methamphetamine hydrochloride.
- She pleaded not guilty at arraignment on July 31, 2015.
- Buy-Bust Operation and Seizure
- A confidential informant tipped the Negros Oriental PNP about “Mah-mah” selling “shabu” in Barangay Cadawinonan. PO1 Jed Delbo confirmed via surveillance.
- On July 21, 2015, around 3:50 p.m., Delbo (poseur buyer) and the CI met accused-appellant; Delbo handed P₵500 marked buy-bust money and received one sachet of crystalline substance. Backup ran in; Delbo announced his authority; arrested her.
- Delbo marked the purchased sachet “MC-BB 7/21/15,” recovered a plastic container with 11 sachets marked “MC-P1 7/21/15” to “MC-P11 7/21/15,” and seized her phone.
- Inventory and photography were conducted at the SOG office (not at the arrest site) in the presence of Delbo, team leader SPO4 Germodo, PO1 Olasiman, DOJ rep. Benlot, media rep. Serion, and the barangay captain; accused-appellant allegedly present but did not appear in photos.
- The sealed envelope of evidence was brought to PDEA lab. PCI Llena tested the sachets and the accused’s urine; both were positive for methamphetamine hydrochloride.
- Defense Version
- Accused-appellant denied wrongdoing; told police she was at the area only to buy gas and was forcibly arrested by officers she later identified as Delbo and Germodo.
- Claimed she saw no drugs until the SOG office; suspected police planted evidence due to her estranged husband’s alleged drug dealings.
- RTC and CA Rulings
- RTC (March 28, 2017) convicted her of illegal sale (life imprisonment + ₱500,000 fine) and illegal possession (life imprisonment + ₱400,000 fine); forfeited seized sachets.
- CA (November 29, 2018) affirmed.
Issues:
- Whether the RTC erred in giving credence to the uncorroborated testimony of PO1 Delbo, which was claimed to be incredible and inconsistent.
- Whether the RTC erred in finding compliance with Section 21, Article II of RA 9165 (chain of custody requirements).
- Whether the evidence was sufficient to prove guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)