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People of the Philippines vs.

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.

Miguel v. People, G.R. No. 227038, July 31, 2017


This case revolves around the illegal possession of dangerous drugs charge against petitioner Jeffrey
Miguel y Remegio. The facts of the case involve a warrantless arrest and subsequent search
conducted by Bantay Bayan operatives, resulting in the seizure of marijuana from the petitioner.
The prosecution alleged that the petitioner was arrested after Bantay Bayan operatives received a
report of a man showing off his private parts at a certain location. Upon approaching the petitioner,
they claimed to have found marijuana in his possession, leading to his arrest and the filing of charges
against him.
However, the petitioner presented a different version of events, claiming that he was merely urinating
in front of his workplace when he was approached and arrested by the Bantay Bayan operatives.
The trial court convicted the petitioner based on the prosecution's version of events, ruling that the
arrest and subsequent search were lawful as they were incidental to the petitioner's arrest for
indecent exposure.
On appeal, the Court of Appeals affirmed the petitioner's conviction, holding that the search and
seizure of the marijuana were valid as they were conducted incidental to a lawful arrest.
However, the Supreme Court, in reviewing the case, found that the arrest and search conducted by
the Bantay Bayan operatives were illegal. The Court noted discrepancies in the testimonies of the
prosecution witnesses and found the petitioner's version of events more credible.
The Court emphasized that a lawful arrest must precede a search, and in this case, there was no
lawful basis for the petitioner's arrest. Therefore, the marijuana seized from the petitioner cannot be
used as evidence against him.
As a result, the Supreme Court granted the petitioner's appeal, reversed the decisions of the lower
courts, and acquitted the petitioner of the charge of illegal possession of dangerous drugs. The Court
ordered the petitioner's immediate release unless he is being lawfully held for any other reason.

Dela Cruz v. People, G.R. No. 209387, January 11, 2016)]


In the case of **ERWIN LIBO-ON DELA CRUZ v. PEOPLE (GR No. 209387, 2016-01-11)**, the
petitioner, Erwin Libo-on Dela Cruz, appealed a decision that found him guilty of possessing
unlicensed firearms during the 2007 election period. Dela Cruz was at a pier in Cebu Domestic Port to
travel to Iloilo when port authorities detected firearms in his bag during routine x-ray scanning. He
was subsequently arrested and charged with violating the Gun Ban under Commission on Elections
Resolution No. 7764.

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.

Marquez v. People, G.R. No. 197207, March 13, 2013


In **Benedicto Marquez y Rayos Del Sol v. People of the Philippines (G.R. No. 197207, March 13,
2013)**, the petitioner, Benedicto Marquez y Rayos Del Sol, appealed the decision of the Court of
Appeals (CA) which affirmed his conviction for illegal possession of marijuana under Section 11, Article
II of Republic Act (R.A.) No. 9165, the Comprehensive Dangerous Drugs Act of 2002.

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.

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