Professional Documents
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Facts: This is a petition for the issuance of a writ of habeas corpus under
Rule 102 of the Rules of Court. Petitioner Reynaldo de Villa, joined by
his son, petitioner-relator June de Villa, seeks a two-fold relief: First, that
respondent Director of Prisons justify the basis for the imprisonment of
petitioner Reynaldo de Villa; and second, that petitioner be granted a new
trial. These reliefs are sought on the basis of purportedly exculpatory
evidence, gathered after performing deoxyribonucleic acid (DNA) testing
on samples allegedly collected from the petitioner and a child born to the
victim of the rape.
Ruling: The Supreme Court ruled granted the appeal filed by the
appellant. It ruled that in all prosecutions for the violation of the
Comprehensive Dangerous Drugs Act of 2002, the existence of the
prohibited drug has to be proved.
The chain of custody rule requires that testimony be presented about every
link in the chain, from the moment the item was seized up to the time it is
offered in evidence. To this end, the prosecution must ensure that the
substance presented in court is the same substance seized from the
accused.
The prosecution failed to show how the seized evidence changed hands
from the time PO1 Vargas turned it over to the investigator up to the time
they were presented in court as evidence. The prosecution did not adduce
evidence on how the evidence was handled or stored before its
presentation at the trial. Since the failure to establish every link in the
chain of custody of the drug compromised its identity and integrity, which
is the corpus delicti of the crimes charged against appellant, his acquittal is
therefore in order.
People of the Philippines v. Reynaldo Belocura y Perez
G.R. No. 173474, August 29, 2012
Associate Justice Lucas Bersamin
Issue: Whether the trial court erred in admitting in evidence the marijuana
despite the illegality of its seizure due to the absence of a valid search
warrant.
The Court holds that the guilt of Belocura for the crime charged was not
proved beyond reasonable doubt. Mere suspicion of his guilt, no matter
how strong, should not sway judgment against him. Every evidence
favoring him must be duly considered. Indeed, the presumption of
innocence in his favor was not overcome. Hence, his acquittal should
follow.
People of the Philippines v. Andrew Roble
G.R. No. 192188, April 11, 2011
Associate Justice Presbitero Velasco, Jr.
Facts: This is an appeal from the July 14, 2009 Decision of the Court of
Appeals (CA) in CA-G.R. CEB CR-H.C. No. 00746, which affirmed
the May 2, 2007 Decision in Criminal Case No. DNO-2989 of the
Regional Trial Court (RTC), Branch 25 in Danao City. The RTC found
accused-appellant Andrew Roble (Roble) guilty of violating Section 5
Article II of Republic Act No. (RA) 9165 or the Comprehensive
Dangerous Drugs Act of 2002.
On or about March 12, 2003 at 6:30 o'clock in the evening more or
less, in Looc, Danao City, Philippines and within the jurisdiction of this
Honorable Court, the above-named accused, in a buy-bust operation, did
then and there willfully, unlawfully and feloniously sell and deliver two
(2) plastic packets containing "shabu" powder/granule a regulated drug
with a total weight of zero point zero six (0.06) gram to a poseur-buyer
for a total consideration of Three Hundred (P300) pesos without any
corresponding license or prescription from the proper authorities as
provided by law; and the aforesaid packets of "shabu" was turned over by
the poseur-buyer to the police as evidence.
After trial, the RTC found Roble guilty of the crime charged. On July 14,
2009, the CA affirmed the judgment of the lower court based on the
time-honored doctrine that the assessment by the trial court of the
credibility of the witnesses and their testimonies deserves great respect.
On June 16, 2003, Gonzales was formally charged in the RTC with a
violation of Section 5, Article II, of Republic Act No. 9165 under the
following information, to wit:
CONTRARY TO LAW.
The absolution of Gonzales should then follow, for we cannot deny that
the observance of the chain of custody as defined by the law was the only
assurance to him that his incrimination for the very serious crime had been
legitimate and insulated from either invention or malice.
Issue: Whether the trial court gravely erred in convicting the accused-
appellant despite the prosecution’s failure to establish the chain of custody
of the alleged confiscated drug.
Ruling: The appeal is bereft of merit. As correctly ruled by the CA, the
prosecution was able to establish the integrity of corpus delicti and the
unbroken chain of custody. PO1 Vargas identified in open court the sachet
of shabu that was offered in evidence against Gerry as the same one she
seized from the latter and marked immediately thereafter in the presence of
the police investigator. The police investigator continued the chain when
he testified that he saw PO1 Vargas making the appropriate markings on
the sachet, as well as issuance of an inventory receipt as evidence of
transfer of custody.
Furthermore, this Court has consistently ruled that even in instances where
the arresting officers failed to take a photograph of the seized drugs as
required under Section 21 of R.A. No. 9165, such procedural lapse is
not fatal and will not render the items seized inadmissible in
evidence. What is of utmost importance is the preservation of the integrity
and evidentiary value of the seized items, as the same would be utilized in
the determination of the guilt or innocence of the accused.
Facts: Before the Supreme Court is an appeal assailing the Decision of the
Court of Appeals, Cagayan de Oro City, (CA). The CA affirmed the
Decision of the Regional Trial Court of Butuan City, Branch 4 (RTC), in
Criminal Case No. 9840 convicting appellant Jose Almodiel alias
"Dodong Astrobal" (accused) of violation of Section 5, Article II (Sale of
Dangerous Drugs) of Republic Act No. 9165 (RA 9165) or The
Comprehensive Dangerous Drugs Act of 2002.
The Information dated 16 May 2003 filed against the accused states:
The RTC found the accused guilty beyond reasonable doubt of violation of
RA 9165. The RTC found that the elements of the crime of illegal sale of
shabu were proven by the prosecution. The CA affirmed the RTC’s
Decision against the accused.
Ruling: The Supreme Court ruled that the appeal lacks merit. In the
prosecution of drug cases, it is of paramount importance that the existence
of the drug, the corpus delicti of the crime, be established beyond
doubt. It is precisely in this regard that RA 9165, particularly its Section
21, prescribes the procedure to ensure the existence and identity of the
drug seized from the accused and submitted to the court.
Facts: This is an appeal from the Decision dated June 29 2010 of the
Court of Appeals (CA), which affirmed the Decision dated June 15,
2007 of the Regional Trial Court RTC) of Laoag City, Branch 13 in
Criminal Case No. 11968-13, finding accused-appellant Garyzaldy
Guzon Guzon) guilty beyond reasonable doubt of the crime of illegal sale
of shabu.
The RTC rendered its Decision finding Guzon guilty as charged. The CA
rendered its Decision denying the appeal. It reasoned that Guzon’s
defenses of denial and frame-up are common and could easily be
fabricated; they could not prevail over the positive identification of the
accused by the police officer who testified for the prosecution.
Facts: The Spouses Vivencio and Teodora Brigole had four children.Two
of them were girls Norelyn, who was born on December 24, 1984, and
her older sister Doneza, who was born in 1983.However, Teodora left
Vivencio and kept custody of their children.
In the morning of March 5, 1995, Norelyn, who was then barely ten
years old, was gathering firewood with the appellant in the latter’s
farmland. While they were nearing a guava tree, the appellant suddenly
boxed her on the stomach. Norelyn lost consciousness. She had her clothes
when she woke up. It was about noon. She had a terrible headache and
felt pain in her vagina. She also had a bruise in the middle portion of her
right leg. The appellant warned her not to tell her mother about it,
otherwise he would kill her. The sexual assaults were repeated several
times so she decided to tell her sister and eventually her mother. The trial
court found the accused guilty of the crime rape and sentenced him to
death.
Issue: Whether the accused is guilty of the crime charged against him.
Ruling: The Supreme Court found the accused guilty of the crime charged
against him. For the accused to be held guilty of consummated rape, the
prosecution must prove beyond reasonable doubt that: 1) there had been
carnal knowledge of the victim by the accused; 2) the accused achieves
the act through force or intimidation upon the victim because the latter is
deprived of reason or otherwise unconscious.
This Court has ruled that when a woman states that she has been raped,
she says in effect all that would necessary to show rape did take place.
However, the testimony of the victim must be scrutinized with extreme
caution. The prosecution must stand or fall on its own merits.
Facts: Petitioner Artemio Yadao (Yadao) prays for the reversal of the
decision finding him "guilty beyond reasonable doubt of the crime of
homicide as charged in the information defined and penalized under
Article 249 of the Revised Penal Code for the death of Deogracias
Gundran (Gundran), and sentencing him to suffer the "indeterminate
penalty of FOUR (4) YEARS, TWO (2) MONTHS and ONE (1) DAY
of prision correccional in its maximum period, as Minimum to EIGHT
(8) YEARS of prision mayor in its minimum period, as Maximum.
During the trial of the case, Dr. Alambra testified for the defense. She
stated under oath that immediately after the death of the victim, she
conducted the autopsy of the body of said victim; that during the
procedure, she made an internal, as well as external, examination of the
body of the victim. Dr. Alambra then confirmed that the cause of death of
the victim was cardio-respiratory arrest due to pulmonary tuberculosis that
was already so far advanced with massive pleural adhesions.
Issue: Whether the accused is guilty of the crime charged against him.
Ruling: In convicting Petitioner Yadao, the RTC and the Court of Appeals
principally relied upon the testimony of Dr. Llavore in addition to the
latter's autopsy report, both essentially stating that the injury sustained by
the victim in the head caused massive hematoma and/or cerebral edema.
However, we find said testimonial and documentary evidence utterly
insufficient on which to anchor a judgment of conviction for homicide.
From the foregoing, the inevitable conclusion is that the guilt of petitioner
Yadao has not been proved beyond reasonable doubt. The facts of the
case, the autopsy reports, as well as the testimony of Dr. Llavore do not
definitely establish that the assault was the proximate cause of the death of
the victim. Even assuming for the sake of argument that the blow inflicted
on the head of the victim resulted in an edematous condition of the brain,
petitioner Yadao would still not be held liable for the death as the
prosecution failed to present proof that said act was the efficient and
proximate cause of the victim's demise.
The trial court found the accused guilty beyond reasonable doubt of the
crime charged.
Issue: Whether or not the accused is guilty of the crime charged beyond
reasonable doubt.
Facts: This is a petition for certiorari under Rule 45 of the Rules of Court
filed by Rolito Rabanal (petitioner) impugning the (1) Decision of the
Court of Appeals dated 31 March 2003 affirming the Decision of the
Regional Trial Court (RTC) of Quezon City, Branch 97 convicting
petitioner of homicide and (2) its Resolution dated 11 November 2003
denying his motion for reconsideration.
Petitioner, along with Salvador Impistan alias "Ador" and Eloy Labatique
(Eloy) were charged with homicide in an Information which reads:
That on or about the 16th day of November, [sic] 1986, in Quezon City,
Philippines, and within the jurisdiction of this Honorable Court, the above-
named accused conspiring together, confederating with [and] mutually
helping each other, with intent to kill, with evident premeditation and
treachery, and without any justifiable cause, did then and there willfully,
unlawfully and feloniously attack, assault and employ personal violence
upon the person of FELIPE SALES Y NACHOR by then and there
stab[b]ing him with a bladed weapon hitting the victim on different parts
of his body thereby inflicting upon him serious and mortal wounds which
were the direct and immediate cause of his death, to the damage and
prejudice of the [heirs] of the said FELIPE SALES Y NACHOR in such
amount as may be awarded under the provisions of the Civil Code.
Ruling: As to the first issue, we agree with the Court of Appeals that
said exhibits are admissible in evidence. We note that the questioned
exhibits consist mostly of Nora's medical records, which were produced
by the hospital during trial pursuant to a subpoena duces tecum.
Petitioner's counsel admitted the existence of the same when they were
formally offered for admission by the trial court. In any case, given the
particular circumstances of this case, a ruling on the negligence of
petitioner may be made based on the res ipsa loquitur doctrine even in the
absence of such additional exhibits.
The Hippocratic Oath mandates physicians to give primordial
consideration to the well-being of their patients. If a doctor fails to live up
to this precept, he is accountable for his acts. This notwithstanding, courts
face a unique restraint in adjudicating medical negligence cases because
physicians are not
guarantors of care and, they never set out to intentionally cause injury to
their patients. However, intent is immaterial in negligence cases because
where negligence exists and is proven, it automatically gives the injured a
right to reparation for the damage caused.
For almost 10 days, she just kept the incident to herself until
she was able to muster enough courage to tell her brother-
in-law, Orlando Pioquinto, who in turn informed Alejandro,
the victim’s father, about the rape of his daughter. Alejandro
did not waste time and immediately asked Escelea to see a
doctor for medical examination and eventually file a
complaint after the issuance of the medical certificate. Turco,
meanwhile, alleged that he and Escelea were
sweethearts.The trial court found Turco guilty of the charge.
In his appeal, Turco argues, among others, that no actual
proof was presented that the rape of the complainant
actually happened considering that although a medical
certificate was presented, the medico-legal officer who
prepared the same was not presented in court to explain the
same.
Issue/s: a) Whether or not the lower court erred in finding
the appellant guilty of rape. b) Whether or not the
appellant’s contention that the medical certificate may not
be considered is with merit.
ONG v. CA
272 SCRA 725
Justice Mendoza
RAMOS v. CA
321 SCRA 584
Justice Kapunan
Dissent
The DNA profiles from the vaginal fluid matched the DNA
profiles from Thomas’ blood. During the trial, Thomas called
no witnesses in his defense, but he advanced his theory of
defense throughout the trial that the victim’s husband
caught him and the victim having consensual intercourse,
that he ran away to avoid an altercation with the husband,
and that the husband, in a jealous rage, killed the wife.