Case Digest (G.R. No. 202692)
Facts:
Edmund Sydeco y Sionzon v. People of the Philippines, G.R. No. 202692, November 12, 2014, Supreme Court Third Division, Velasco Jr., J., writing for the Court. The petition is a Rule 45 petition for review of the Court of Appeals' decision and resolution dated December 28, 2011 and July 18, 2012 respectively, which affirmed the Regional Trial Court's (RTC) affirmation of the Metropolitan Trial Court's (MeTC) conviction of petitioner for drunk driving and resisting arrest.On June 11–12, 2006 petitioner was stopped at a police checkpoint along Roxas Boulevard corner Quirino Avenue, Malate, Manila. Separate informations were filed in the MeTC (Crim. Case Nos. 052527‑CN and 052528‑CN) charging him with violation of Section 56(f) of Republic Act No. 4136 (driving under the influence of liquor) and Article 151 of the Revised Penal Code (resistance and disobedience), respectively. At arraignment petitioner pleaded not guilty. The MeTC tried the consolidated cases and convicted him on June 26, 2009, imposing fines and imprisonment.
The prosecution presented testimony of police officers (including SPO4 Efren Bodino), the investigating officer, and the medical records custodian of Ospital ng Maynila, and introduced a joint affidavit of arrest and a medical certificate by Dr. Harvey Balucating indicating "alcoholic breath." The defense presented petitioner, his wife, and a passenger (Joenilo Pano), who alleged that police used force, that petitioner was not examined by Dr. Balucating, and that empty beer cases in the trunk came from petitioner’s restaurant.
Petitioner appealed to the RTC (Manila, Branch 12). By Decision dated February 22, 2010 the RTC affirmed the MeTC, holding that police observations and testimony sufficed to establish intoxication and that a single credible witness may support conviction. The RTC denied reconsideration. Petitioner then sought review in the Court of Appeals...(Pro-only)
Issues:
- Did the Court of Appeals err in upholding the presumption of regularity in the performance of duties by the police officers?
- Did the Court of Appeals err in giving weight to the Medical Certificate issued by Dr. Harvey Balucating in the absence ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)