Case Summary (G.R. No. 179594)
Facts of the Case
Around 5:30 PM on the incident date, law enforcement officers were informed about a marijuana transaction. Upon arrival, officers Luciano and Caraan observed Bati and Marquez engaging in the exchange of marijuana for money at a distance of approximately 40 to 50 meters. After the transaction, Marquez was pursued, initially denying possession of any illegal items until he eventually produced marijuana wrapped in newspaper from his pants. Bati was subsequently arrested after admitting to selling marijuana to Marquez for P190.00. The confiscated money was marked by Luciano, while the marijuana was submitted to the PC Crime Laboratory for forensic examination, confirming its identity as marijuana.
Criminal Charges
An Information was filed against Regalado Bati in the Regional Trial Court, charging him with violating Section 4, Article II of Republic Act No. 6425 for the illegal distribution and sale of marijuana. After a trial, the court found Bati guilty beyond a reasonable doubt and sentenced him to life imprisonment, a fine of P25,000.00, and costs. The trial court justified the conviction based on the strong evidence presented by the prosecution.
Appellant's Arguments
Bati appealed the trial court's decision, arguing multiple errors:
- The arrest was illegal and violated his constitutional rights, rendering the evidence inadmissible.
- The failure to present Warner Marquez and the civilian informer for testimony resulted in the suppression of exculpatory evidence.
- The testimonies of the prosecution witnesses contained contradictions that undermined the case.
Legal Basis for Arrest
The court addressed the first argument by citing Section 5 of Rule 113 of the Rules on Criminal Procedure, which permits warrantless arrests under certain conditions. Since the officers witnessed the crime firsthand, their action fell under the lawful provisions of a ‘hot pursuit’ arrest. The search that followed was deemed an incidental search relevant to the valid arrest.
Non-Presentation of Witnesses
The court dismissed the second argument regarding the non-presentation of Marquez and the civilian informer. It concluded that their testimonies would merely provide cumulative evidence, as there were already sufficient eyewitness accounts from the arresting officers establishing Bati’s involvement in the drug transaction.
Evaluation of Evidence
Addressing the third argument regarding perceived inconsistencies and contradictions in witness testimonies, the court determined that such discrepancies did not signifi
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Factual Background
- On July 27, 1986, at approximately 5:30 PM, Patrolmen Jose Luciano, Angelito Caraan, Nelson Dimatulac, and Democrito Cuenca received information from a civilian informer regarding a marijuana transaction occurring in Dona Crispina Park Subdivision, Barangay Bagong Bayan, San Pablo City.
- Patrolmen Luciano and Caraan proceeded directly to the location, while Dimatulac and Cuenca were dispatched to the nearby Bolante Section of the public market.
- Upon arrival, Luciano and Caraan observed Regalado Bati and Warner Marquez about 40-50 meters away, engaged in a transaction where Marquez handed something to Bati, who then placed the item in his pocket.
- After the transaction, Marquez was followed by the police officers, who apprehended him after he attempted to flee on a bicycle. Initially, Marquez denied receiving anything from Bati but later produced a pink plastic bag containing marijuana.
- Marquez confessed to buying marijuana for P190.00 from Bati, leading to Marquez's arrest and subsequent pursuit of Bati by Luciano and Caraan.
- Bati was arrested after admitting to selling marijuana to Marquez, and P190.00 was confiscated from him.
Arrest and Seizure
- The marijuana and cash were turned over to Sgt. Bayani Yte, Chief of the Intelligence and Investigation Section of the San Pablo City Police Station, after initial processing by the arresting officers.
- The marijuana was examined by Forensic Chemist Rosalinda Royales, confirming it contained marijuana.
- An Information was filed against Bati, charging him with violating Section 4, A