Professional Documents
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Alamada Macabando
In the case of People of the Philippines vs. Alamada Macabando, the appellant was convicted of
arson. The prosecution's evidence presented a series of events that strongly indicated the appellant's
guilt: he was seen behaving violently near his house, threatening to burn it down, preventing
neighbors from extinguishing the fire, and carrying a gun during the incident. Additionally, the
investigation concluded that the fire was intentional and started in the appellant's house.
Despite the lack of direct evidence, the court found the circumstantial evidence compelling enough to
establish the appellant's guilt beyond a reasonable doubt. The combination of these circumstances
led to the conclusion that the appellant was the one who set fire to his house.
However, the court modified the conviction from destructive arson to simple arson under Section 3(2)
of Presidential Decree No. 1613. This decision was based on the fact that the appellant's act, while
resulting in damage to multiple dwellings, did not demonstrate the same level of perversity or
viciousness as acts typically associated with destructive arson. Simple arson, as defined in the decree,
applies to intentional burning of inhabited houses or dwellings.
As a result, the court imposed an indeterminate penalty of ten (10) years and one (1) day of prision
mayor as a minimum, to sixteen (16) years and one (1) day of reclusion temporal as a maximum on
the appellant.
Furthermore, the court did not award actual damages to the offended parties due to the lack of
concrete evidence supporting such claims.
In summary, while the appellant's guilt for arson was affirmed, the crime was downgraded to simple
arson, leading to a modification in the penalty imposed.
Dela Cruz argued that the search conducted by port authorities was unreasonable and that he did not
waive his right against unreasonable searches and seizures. He contended that he had no intention to
relinquish his right, and there was an opportunity for someone else to place the firearms in his bag
during the time it was left unattended.
The court ruled that the search conducted by port authorities was reasonable and did not violate Dela
Cruz's constitutional rights. The court emphasized that port security measures, including routine
baggage inspections, are necessary to ensure the safety of travelers and vehicles within the port. Dela
Cruz voluntarily submitted his bag for inspection by placing it on the x-ray scanning machine, and he
had the option not to travel if he did not want his bag inspected.
Moreover, the court found that Dela Cruz voluntarily consented to the search conducted by port
authorities. He did not contest the results of the x-ray scan and willingly allowed port personnel to
inspect his bag. Therefore, there was a valid waiver of his right against unreasonable searches and
seizures.
In conclusion, the court affirmed the decision finding Dela Cruz guilty of possessing unlicensed
firearms, as the search conducted by port authorities was reasonable and valid, and Dela Cruz
voluntarily consented to the search.
The Regional Trial Court (RTC) found Marquez guilty based on evidence that he was caught with 1.49
grams of marijuana in his possession at a high school where he worked. The court held that the
prosecution was able to establish all the elements of illegal possession of dangerous drugs, including
Marquez's knowing possession without legal authority.
Marquez appealed, arguing that the police failed to comply with the required procedures in handling
the seized drugs and that the chain of custody over the evidence was broken.
The CA upheld Marquez's conviction, finding that the prosecution successfully established all the
elements of illegal possession of dangerous drugs. It ruled that non-compliance with certain
procedures under R.A. No. 9165 does not necessarily invalidate the prosecution's case as long as the
integrity and evidentiary value of the seized evidence are preserved. The court also determined that
the chain of custody over the confiscated marijuana was not broken based on the established
sequence of events and the testimonies of witnesses.
Regarding the failure to strictly comply with the provisions of Section 21 of R.A. No. 9165, the court
held that this does not render the seized items inadmissible as long as the integrity and evidentiary
value of the evidence are preserved. The court noted that the person who initially seized the drugs
was a guidance counselor at the school where Marquez worked, and her failure to mark the seized
sachets did not weaken the prosecution's case since she was able to establish that she handed the
seized drugs to the police upon their arrival.
Ultimately, the court affirmed Marquez's conviction and the penalty imposed by the RTC, as it was in
accordance with the law.
In summary, Marquez's appeal was dismissed, and his conviction for illegal possession of marijuana
was upheld by the CA.