Case Summary (G.R. No. 78903)
Charges and Initial Proceedings
The accused-appellants were charged based on a complaint filed on August 3, 2009, for the unlawful transportation of heroin. They faced an initial hearing where they filed motions to quash the charges, arguing that their arrest and subsequent search of their belongings were conducted unlawfully. The Regional Trial Court (RTC) of Pasay City denied these motions, leading to their arraignment where both pleaded not guilty.
Evidence Presented
The prosecution presented testimony from Special Investigator Joel Otic and other agents of the National Bureau of Investigation (NBI), detailing their operations stemming from a tip-off about Vargas carrying heroin. On the day of the incident, they monitored the accused at the hotel, witnessed their interactions, and subsequently stopped Alberto at NAIA, where they believed he possessed illegal drugs. The NBI's search at their office revealed heroin in the luggage.
Ruling of the Regional Trial Court
On March 11, 2014, the RTC convicted both accused-appellants, sentencing them to life imprisonment and imposing a fine of P500,000 each. The court found sufficient evidence of conspiracy and active participation in the transportation of illegal drugs, emphasizing that the testimony provided by NBI agents was credible and corroborated by their operational procedures.
Appeal to the Court of Appeals
The accused-appellants appealed the RTC decision to the Court of Appeals (CA), which affirmed the conviction on May 22, 2018. The CA reiterated that the transportation of illegal drugs did not require proof of intent to commit the crime, as the nature of the offense was mala prohibita. The court also found that the evidence confirmed the illegal act, and upheld the presumption of regularity in the NBI’s operations.
Arguments in the Appeal
The accused-appellants, through their counsel, alleged various procedural and substantive errors. Vargas claimed she was unlawfully arrested without a warrant, and her rights were violated during the process. Alberto contended that he was forcibly taken into custody and not allowed to reject the NBI's invitation. They also challenged the legality of the search of the black trolley bag, asserting it was a violation of their Fourth Amendment rights against unreasonable searches and seizures.
Ruling of the Supreme Court
The Supreme Court dismissed the appeal, affirming the decisions of the lower courts. It held that the movement of heroin constituted illegal transportation, meeting the requirements for conviction under R.A. 9165. The Court found no merit in the arguments claiming illegal arrest or search, determining that both accused voluntarily submitted to the NBI's procedures and consented to the search of their belongings, fulfilling the legal standards for a warrantless search under exigent circumstances.
Complia
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Case Background
- The case involves an ordinary appeal by accused-appellants Salvador Agunday Alberto II (Alberto) and Mary Jane Turalde Vargas (Vargas).
- The appeal concerns the Decision dated May 22, 2018, and Resolution dated August 28, 2018, from the Court of Appeals (CA), which upheld the Regional Trial Court's (RTC) conviction of the accused-appellants for violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
- The RTC found both accused guilty beyond reasonable doubt and sentenced them each to life imprisonment and a fine of Five Hundred Thousand Pesos (₱500,000.00).
Charges and Initial Proceedings
- The accused-appellants were charged with transporting 887.88 grams of heroin, a dangerous drug, without legal authority.
- The Information was filed on August 3, 2009, detailing the alleged crime occurring on July 31, 2009, in Pasay City, Metro Manila.
- Both accused-appellants filed motions to quash the arrest and search, arguing they were conducted illegally, which the RTC denied.
Admission of Facts
- During the preliminary conference, both parties admitted vital facts, including the identity of the accused, the nature of the arrest, and the qualifications of the forensic expert.
- The prosecution established that the heroin was found in two envelopes marked as MEE-2 and MEE-3, weighing a total of 887.88 grams.
Prosecution's Evidence
- Key witnesses included Special Investigator (SI) Joel Otic, SI Nelson Saul, SI Melvin Escurel, and Attorney Fatima Liwalug.
- The investigation began with information from a Filipino informant about Vargas tr