Case Summary (G.R. No. 90452)
Applicable Law
The legal framework governing the case includes the Dangerous Drugs Act of 1972 (RA 6425) and its subsequent amendments, particularly those brought about by Presidential Decree Nos. 44, 1675, 1683, 1708, and Batas Pambansa Blg. 179, which establish the definitions and penalties for drug-related offenses.
Factual Background of the Incident
On the evening of October 20, 1983, law enforcement personnel from the INP Ifugao Command conducted a buy-bust operation following information about a planned sale of marijuana. The operation was spearheaded by Lt. Pedro Dulnuan and involved multiple undercover officers. They encountered the accused, Mario Jaymalin, who was reported to have approached them under the pretense of selling marijuana. During the sale, an altercation occurred involving Mario's brother, Francisco, who fired upon the police, leading to a series of events that resulted in Francisco's death and Mario’s subsequent arrest.
Prosecution's Evidence
During the trial, the prosecution presented evidence, including testimonies from law enforcement officers who conducted the operation. The marijuana was seized and later analyzed, confirming its nature. Two officers, Lt. Danao and Cpl. Kimmayong, testified about the transaction and the arrest, stating that they had identified the illegal substance recovered from Mario as marijuana.
Defense's Testimony
The defense presented an alternative narrative, with Mario asserting that he was merely looking for his daughter and stumbled into the situation unintentionally. He claimed not to know his brother during the confrontation. However, his defense narrative was deemed inconsistent and implausible, especially given the circumstances leading to his arrest.
Trial Court Decision
The Regional Trial Court found Mario Jaymalin guilty of violating the Dangerous Drugs Act, sentencing him to reclusion perpetua or life imprisonment and imposing a fine of P20,000. The verdict was challenged by the defendant on the grounds of alleged inconsistencies in the prosecution's evidence and claims of wrongful arrest.
Court of Appeals Findings
The appellate court conducted a thorough examination of the alleged inconsistencies highlighted by the defense. It concluded that the discrepancies were minor and did not undermine the case's fundamental credibility, as there was significant corroboration among the testimonies regarding critical facts of the case. The court reinforced that minor variances in witness recollections over time are common and should not negate the core integrity of their accounts.
Conclusion of the Court
Upon
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Case Overview
- The case revolves around the conviction of Mario Jaymalin for violation of the Dangerous Drugs Act (RA 6425).
- The incident in question occurred during a buy-bust operation that escalated into a confrontation resulting in the death of Jaymalin's brother, Francisco.
- The trial culminated in a decision by the Regional Trial Court of Lagawe, Ifugao, which sentenced Jaymalin to reclusion perpetua or life imprisonment and a fine of P20,000.
Charges and Information
- Mario Jaymalin was charged with drug pushing, specifically for possessing and intending to sell approximately 7.5 kilos of marijuana.
- The information filed against him detailed the date, location, and nature of the offense, emphasizing his intent to gain from the illegal sale of the substance.
Background of the Incident
- On October 20, 1983, law enforcement received intelligence about a planned sale of marijuana in Kiangan, Ifugao.
- A team from the INP Ifugao Command was organized to conduct surveillance and apprehend the alleged marijuana dealers.
- The operation involved undercover officers posing as buyers, leading to an encounter with Jaymalin, who approached them regarding the sale.
The Buy-Bust Operation
- The undercover officers met at Kiangan Central School, where they were briefed before heading to St. Joseph School's compound.
- At around 8:30 p.m., Jaymalin approached the officers, con