Case Digest (G.R. No. 229380) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Leniza Reyes y Capistrano v. People of the Philippines, petitioner Leniza Reyes was charged by Information dated November 6, 2012 before the Regional Trial Court (RTC) of Binangonan, Rizal, with Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165. The prosecution narrated that at around 8:00 p.m. police officers patrolling Barangay Looc, Cardona, Rizal, acted on a tip from two teenagers that “a woman with long hair and a dragon tattoo” had just bought shabu in Barangay Mambog. Reyes, matching that description and smelling of liquor, was stopped. When asked if she had shabu, she allegedly turned away and produced a small sachet containing white crystalline substance. PO1 Jefferson Monteras seized the sachet, marked it “LRC-1,” conducted inventory and photography before Barangay Captain Manolito Angeles, then forwarded it to the provincial crime lab, where 0.04 gram of methamphetamine hydrochloride was confirmed. Reyes denied the charge, Case Digest (G.R. No. 229380) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Circumstances of Arrest
- On November 6, 2012, petitioner Leniza Reyes y Capistrano was charged with illegal possession of 0.04 gram of methamphetamine hydrochloride (shabu) in Cardona, Rizal, in violation of Section 11, Article II of RA 9165.
- At around 8:00 PM, Police Officer 1 (PO1) Jefferson Monteras, while patrolling with colleagues in Barangay Looc, received a tip from two teenagers about a woman with long hair and a dragon tattoo who had just bought shabu in Barangay Mambog. They encountered Reyes—who smelled of liquor—asked if she had shabu, and she allegedly turned, retrieved a heat-sealed sachet from her breast area, and handed it over.
- Procedural History
- The seized sachet was marked “LRC-1,” inventoried and photographed before Barangay Captain Manolito Angeles, then submitted to the Rizal Provincial Crime Laboratory, which confirmed it contained 0.04 gram of methamphetamine hydrochloride.
- In RTC Crim. Case No. 12-0627, Branch 67, Binangonan, Rizal, the trial court (June 16, 2014) convicted Reyes of possessing 0.11 gram of shabu, sentencing her to 12 years and 1 day to 13 years imprisonment and a P300,000 fine.
- On appeal, the Court of Appeals (CA) (May 20, 2016) affirmed the conviction, adjusted the quantity to 0.04 gram, and modified the penalty to 12 years and 1 day to 14 years and 8 months. A motion for reconsideration was denied (January 11, 2017).
Issues:
- Whether Reyes’s conviction for Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165 should be upheld despite alleged defects in her warrantless arrest, search, and chain of custody.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)