Case Summary (G.R. No. L-65189)
Charges and Sentencing
The accused were charged under the Dangerous Drugs Act of 1972, specifically violating Section 4 in relation to Section 21. Duhan and Recla received sentences of reclusion perpetua and a fine of P20,000 without subsidiary imprisonment, while Reyes, who was a minor (16 years old) at the time of the offense, was sentenced to 12 years and 1 day of prision mayor and a fine of P10,000, also without subsidiary imprisonment. All three were ordered to pay proportionate costs.
Factual Background
The prosecution's case was built on evidence provided by a confidential informer. On June 29, 1982, the informer approached Police Station No. 5 in Manila, claiming she could buy marijuana from the accused. Armed with marked P5 bills, the police followed the informer to the suspected site. Upon arrival, the police observed the accused engage in a transaction where marijuana leaves and a cigarette were allegedly exchanged for the marked bills. After the transaction, the police arrested the three individuals and found additional marijuana on one of the accused.
Defense and Denial of Charges
The appellants contended that the prosecution had not proven their guilt beyond a reasonable doubt. They argued for acquittal based on the principle that a conviction must rest upon the strength of the prosecution's evidence. They presented a narrative that contradicted the prosecution's claims, alleging that the police had wrongfully arrested them during a saturation drive and subjected them to physical abuse. The appellants stated that no drugs were found on them at the moment of their arrest, and they maintained their innocence throughout, claiming misconduct and coercion by police officers.
Testimonies and Key Evidence
Support for the defense came from witness testimonies, including that of Duhan's mother, who attested to her son’s innocence and alleged police misconduct. The witness corroborated the appellants' claims of being unjustly arrested while engaging in lawful activities and being subjected to maltreatment during police custody. Furthermore, the defense highlighted inconsistencies in the testimony provided by the lone prosecution witness, underscoring the lack of credible evidence against the appellants.
Court's Analysis and Findings
Upon reviewing the evidence presented, the Court concluded that the prosecution failed to establish the guilt of the appellants beyond reasonable doubt. Additionally, it was noted that the trial court erred in admitting the Booking and Information Sheets as evidence against the appellants. The court stressed that any verbal admissions sought to be attrib
...continue readingCase Syllabus (G.R. No. L-65189)
Case Overview
- Court: Supreme Court of the Philippines, First Division
- Date: May 28, 1986
- G.R. No.: 65189
- Parties:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellants: Jose O. Duhan, Manuel Recla, Roger Reyes
- Background: The accused were found guilty by the Regional Trial Court of Manila of violating the Dangerous Drugs Act of 1972, resulting in severe penalties, including reclusion perpetua for two appellants and a lengthy prison term for the minor appellant.
Charges and Penalties
- Charges: Jointly selling or offering for sale prohibited drugs (marijuana) without legal authorization.
- Penalties:
- Jose Duhan and Manuel Recla:
- Sentence: Reclusion perpetua
- Fine: ₱20,000
- No subsidiary imprisonment in case of insolvency
- Roger Reyes (16 years old at the time of the offense):
- Sentence: 12 years and 1 day of prision mayor
- Fine: ₱10,000
- No subsidiary imprisonment in case of insolvency
- Jose Duhan and Manuel Recla:
- Additional Costs: All three appellants were sentenced to pay proportionate costs.
Factual Background of the Case
- Incident Date: June 29, 1982
- Location: City of Manila
- Events:
- An 18-year-old female informer approached the police, claiming she could buy marijuana from the appellants.
- Police operatives provided the informer with marked ₱5.00 bills and followed her to the suspected area.
- Upon arrival, the informer engaged in negotiations with the appellants, where the exchange of marijuana for marked bills occurred.
- The police arrested the appellants shortly after the transaction, seizing marijuana and marked bills during the arrest.
Prosecution's Evidence
- Key Evidence Presented:
- Testimonies regarding the transaction and subsequent arrest.
- Forensic examination confirming the substance as m