Professional Documents
Culture Documents
ELMER AVANCENA
[T]he fact that the victim voluntarily went with the accused [does] not remove the
element of deprivation of liberty [if] the victim went with the accused on a false
inducement without which the victim would not have done so. Rizaldo would not have
gone with the accused-appellants had they not misrepresented themselves as
Philippine Drug Enforcement Agency agents who allegedly caught him selling illegal
drugs.
PEOPLE OF THE PHILIPPINES vs. SEGFRED L. OROZCO
Accused-appellant does not dispute being at the scene of the crime. He testified to
taking a knife, giving chase, and stabbing the decedent. There is evidence beyond
reasonable doubt that the victim was subdued by the decedent and his companions.
Thus, they employed means to weaken the victim's defense, constituting treachery.
PEOPLE OF THE PHILIPPINES vs. NADY MAGALLANO, JR.
"The essence of treachery is the swift and unexpected attack on the unarmed victim
without the slightest provocation on his part." For treachery to be appreciated as a
qualifying circumstance, two (2) things must be proven: (1) that during the attack,
the victim could not have defended himself or herself from the offender; and (2) that
the offender deliberately chose a form of attack which would render him or her
immune from risk or retaliation by the victim.
PEOPLE OF THE PHILIPPINES vs. NANCY LASACA RAMIREZ
In People v. De Dios, the Court held that it did not matter that there was no threat,
force, coercion, abduction, fraud, deception or abuse of power that was employed by
De Dios when she involved AAA in her illicit sexual trade. AAA was still a minor when
she was exposed to prostitution by the prodding, promises and acts of De Dios.
Trafficking in persons may be committed also by means of taking advantage of the
persons' vulnerability as minors, a circumstance that applied to AAA, was sufficiently
alleged in the information and proved during the trial. This element was further
achieved through the offer of financial gain for the illicit services that were provided
by AAA to the customers of De Dios.
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police officers, especially when what had been allegedly seized from accused-
appellant was only 0.0604 grams of shabu. Recent cases have highlighted the need
to ensure the integrity of seized drugs in the chain of custody when only a miniscule
amount of drugs had been allegedly seized from the accused.
In People v. Holgado, this Court held that "[c]ourts must employ heightened scrutiny,
consistent with the requirement of proof beyond reasonable doubt, in evaluating
cases involving miniscule amounts of drugs [as] they can be readily planted and
tampered."
Non-observance of the mandatory requirements under Section 21 of Republic Act No.
9165 casts doubt on the integrity of the shabu supposedly seized from accused-
appellant. This creates reasonable doubt in the conviction of accused-appellant for
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guarantee "against planting of evidence and frame up." In other words, they are
"necessary to insulate the apprehension and incrimination proceedings from any taint
of illegitimacy or irregularity."
PEOPLE OF THE PHILIPPINES vs. KING REX A. AMBATANG
In fine, the age-old rule is that the task of assigning values to the testimonies of
witnesses and weighing their credibility is best left to the trial court which forms first-
hand impressions as witnesses testify before it. It is thus no surprise that findings
and conclusions of trial courts on the credibility of witnesses enjoy, as a rule, a badge
of respect, for trial courts have the advantage of observing the demeanor of
witnesses as they testify. We thoroughly review the records of the case, including the
transcript of stenographic notes and we find no cogent reason to overturn the
probative value given by the trial court on the testimonies of the prosecution
witnesses. Hence, we sustain the guilty verdict against herein accused-appellant.
PEOPLE OF THE PHILIPPINES vs. JAIME SEGUNDO
Although the miniscule quantity of confiscated illicit drugs is solely by itself not a
reason for acquittal, this instance accentuates the importance of conformity to
Section 21 that the law enforcers in this case miserably failed to do so. If initially
there were already significant lapses on the marking, inventory, and photographing
of the alleged seized items, a doubt on the integrity of the corpus
delicti concomitantly exists. For this reason, this Court acquits Segundo as his guilt
was not proven beyond reasonable doubt.
Moreover, the presumption of regularity in the performance of their duties "will never
be stronger than the presumption of innocence in favor of the accused. Otherwise, a
mere rule of evidence will defeat the constitutionally enshrined right of an accused
to be presumed innocent."
PEOPLE OF THE PHILIPPINES vs. RAMON FRANCICA
No amount, especially not the P50.00 paid by the accused for sexually abusing his
11-year-old victim, will ever compensate for her trauma. The depravity of a grown
man in taking advantage of a child's trust and innocence and her family's poverty to
repeatedly rape her rightfully deserves condemnation and the most severe
punishment that can be meted out under the law.
The absence of external signs or physical injuries on the complainant's body does not
necessarily negate the commission of rape, hymenal laceration not being, to repeat,
an element of the crime of rape. A healed or fresh laceration would of course be a
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compelling proof of defloration. What is more, the foremost consideration in the
prosecution of rape is the victim's testimony and not the findings of the medico-legal
officer. In fact, a medical examination of the victim is not indispensable in a
prosecution for rape; the victim's testimony alone, if credible, is sufficient to convict.
PEOPLE OF THE PHILIPPINES vs. PEDRITO ORDONA
To qualify the killing of a person to the crime of murder, evident premeditation must
be proven with reasonable certainty. Facts regarding "how and when the plan to kill
was hatched" are indispensable. The requirement of deliberate planning should not
be based merely on inferences and presumptions but on clear evidence.
PEOPLE OF THE PHILIPPINES vs. EDGARDO ROYOL
Complete and utter noncompliance with the chain of custody requirements of
Republic Act No. 9165, or the Comprehensive Dangerous Drugs Act of 2002
(Comprehensive Dangerous Drugs Act), inescapably leads to an accused's acquittal.
Conviction cannot be sustained by a mere presumption of regularity and the
approximation of compliance.
PEOPLE OF THE PHILIPPINES vs. ROLANDO TERNIDA
The failure of law enforcers in buy-bust operations to photograph seized drugs in
accordance with Article II, Section 21 of Republic Act No. 9165, combined with the
prosecution's failure to address this omission, raises doubt on the identity of the
drugs seized, especially when the amount of dangerous drugs allegedly taken from
the accused is minuscule.
ARIEL LOPEZ vs. PEOPLE OF THE PHILIPPINES
To sustain a conviction for cattle-rustling, the identity of the stolen cattle must be
proven with certainty. Otherwise, the accused must be acquitted on the ground of
reasonable doubt.
Further, a "request for appearance" issued by law enforcers to a person identified as
a suspect is akin to an "invitation." Thus, the suspect is covered by the rights of an
accused while under custodial investigation. Any admission obtained from the
"request for appearance" without the assistance of counsel is inadmissible in
evidence.
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Discrepancies, not being elements of the crime of rape, do not diminish the credibility
of AAA's declarations. Jurisprudence has held "youth and immaturity [to be] badges
of truth and sincerity" and has generally given leeway to minor witnesses when
relating traumatic incidents of the past.
PEOPLE OF THE PHILIPPINES vs. ABUNDIO M. SARAGENA
When the quantity of the confiscated substance is miniscule, the requirements of
Section 21 of Republic Act No. 9165, otherwise known as the Comprehensive
Dangerous Drugs Act of 2002, must be strictly complied with.
The prosecution's failure to present the police officer who acted as the poseur-buyer
in the buy-bust operation, which allegedly involved 0.03 grams of shabu, coupled
with the improbability that the two (2) apprehending police officers witnessed the
transaction at night time, engenders reasonable doubt on the guilt of the accused.
The prosecution's failure to sufficiently establish the chain of custody in accordance
with the law further amplifies the doubt on accused's guilt.
PEOPLE OF THE PHILIPPINES vs. SIEGFRED CABELLON CABAÑERO
The marking and identification of the seized dangerous drug is an essential part of
the chain of custody. Absent this step, a gap is created which casts a shadow of doubt
on the identity and integrity of the dangerous drug presented as evidence, creating
reasonable doubt, which must be resolved in favor of the accused.
PEOPLE OF THE PHILIPPINES vs. EMMA BOFILL PANGAN
Section 21 of Republic Act No. 9165, otherwise known as the Comprehensive
Dangerous Drugs Act of 2002, cannot be utilized to frustrate legitimate efforts of law
enforcers. Minor deviations from the mandated procedure in handling the corpus
delicti must not absolve a guilty defendant.
the arresting officers' non-compliance with Section 21 is not fatal, provided that that
there is a justifiable reason for their deviation and that the evidentiary worth of the
seized drugs or articles was preserved. Non-conformity with the mandated
procedures will not make the arrest of the accused illegal or the items seized
inadmissible as evidence. What matters most is that the integrity and evidentiary
worth of the seized articles were maintained since these will be used in resolving the
guilt or innocence of the accused.