Case Summary (G.R. No. 135981)
Factual Background
The prosecution's case was based on a buy-bust operation where Patrolman Lechido, acting as the poseur-buyer, was tasked to purchase marijuana from the respondents. Following a tip-off regarding illegal drug activities by a civilian informant, surveillance was conducted, leading to the apprehension of Madriaga while he was selling marijuana and the subsequent arrest of Pangilinan, who was implicated in the transaction.
Trial Court's Decision
On September 17, 1987, the Regional Trial Court convicted both respondents, sentencing each to thirty years of life imprisonment and a fine of P20,000. Following their conviction, the respondents filed a Notice of Appeal on September 30, 1987, contending various errors made by the trial court.
Points of Appeal
The appellants challenged the trial court's reliance on the testimonies of the prosecution witnesses, arguing inconsistencies in their accounts, particularly regarding the marking of the buy-bust money and the signal for arrest. They also contended that the buy-bust operation was illegal and that the evidence obtained should be inadmissible due to the lack of a search warrant.
Credibility of Testimonies
Despite the appellants’ claims, the court found that the testimonies of Patrolman Lechido were not inconsistently flawed. The testimony clarified that the marked bill was recorded with its serial number and uniquely marked, affirming its identity. Minor discrepancies in the officers' recollections were deemed insufficient to undermine the overall credibility of the prosecution’s presentation of facts.
Legality of Arrest and Search
The court upheld the legal basis for both arrests, asserting they were executed in compliance with Rule 113 of the Revised Rules of Court. Madriaga's arrest was deemed valid as he was caught in the act of selling marijuana, while Pangilinan's arrest was also valid due to his involvement in the transaction. The subsequent search conducted without a warrant was justified as an incident of lawful arrest.
Entrapment vs. Instigation
The appellants argued that they were instigated into committing the crime; however, the court determined that the operation was an entrapment aimed at capturing individuals engaged in illegal drug activities. The respondents' failure to demonstrate that they were i
...continue readingCase Syllabus (G.R. No. 135981)
Case Overview
- The case involves the conviction of respondents Rolando Madriaga y Bautista (alias Olan) and Rolando Pangilinan y Cruz (alias Olan) for violating Section 4, Article II of the Dangerous Drugs Act, Republic Act No. 6425, as amended by Presidential Decree No. 1675.
- The alleged offense occurred on March 27, 1987, in Caloocan City, where the accused were accused of selling dried marijuana flowering tops to a poseur-buyer, Patrolman Reynaldo Lechido.
Charges and Proceedings
- The information was filed in the Regional Trial Court of Caloocan City, Branch 124, docketed as Criminal Case No. C-28540.
- Upon arraignment, both accused pleaded not guilty, leading to a trial where testimonies from prosecution witnesses were heard, including Patrolman Lechido and Corporals Alfredo Rodillas and Wilfredo Tamondong.
Trial Court Decision
- On September 17, 1987, the trial court found both accused guilty beyond reasonable doubt, sentencing them to thirty years of life imprisonment and a fine of P20,000.00, with subsidiary imprisonment in case of insolvency.
- The accused filed a Notice of Appeal on September 30, 1987.
Summary of Facts
- A civilian informant notified the Anti-Narcotics Unit about an individual named