Scribd Logo
Upload

Welcome to Scribd!

  • 31 views

    (CPR) People Vs Edaño, GR No 188133, 07 July 2014 Case Digest

    Uploaded by

    arceo.ezekiel0
    A simple case digest discussing the relevant case issues in relation to the Rules of Criminal Procedure.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    (CPR) People Vs Edaño, GR No 188133, 07 July 2014 Case Digest

    Uploaded by

    arceo.ezekiel0
    31 views2 pages
    A simple case digest discussing the relevant case issues in relation to the Rules of Criminal Procedure.

    Original Title

    [CPR] People vs Edaño, GR No 188133, 07 July 2014 Case Digest

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    A simple case digest discussing the relevant case issues in relation to the Rules of Criminal Procedure.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    31 views2 pages

    (CPR) People Vs Edaño, GR No 188133, 07 July 2014 Case Digest

    Uploaded by

    arceo.ezekiel0
    A simple case digest discussing the relevant case issues in relation to the Rules of Criminal Procedure.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    You are on page 1of 2

    TITLE: People of the Philippines v.

    Oliver Renato Edaño y Ebdane


    DATE: July 7, 2014
    PONENTE: Justice Brion
    HEADING: Warrantless arrest; In flagrante delicto.
    APPELLEE: People of the Philippines
    APPELLANT: Oliver Renato Edaño y Ebdane
    FACTS:
     The appellant was arrested by the police in an entrapment operation at
    McDonalds, West Avenue, Quezon City, for allegedly selling shabu to a female
    informant.
     The police claimed that they recovered a plastic bag containing shabu from the
    appellant’s right hand and a gun from his waist.
     The appellant denied the charges and testified that he was just meeting a friend
    at McDonalds when he was accosted by a man who tried to grab his hand. He
    resisted and ran away, but was caught by the police who planted the evidence
    on him.
    PROCEDURAL HISTORY OF THE CASE
    INFORMATION FILED: Violation of Section 11, Article II of R.A 9165.
    NATURE OF THE CASE: Appeal from the decision of the Court of Appeals affirming the
    conviction of the appellant for violation of Section 11, Article II of Republic Act No.
    9165.
    PROCEDURAL HISTORY
     The Supreme Court reversed and set aside the decision of the Court of Appeals
    and acquitted the appellant for failure of the prosecution to prove his guilt
    beyond reasonable doubt.
     The Court of Appeals affirmed the decision of the Regional Trial Court finding the
    appellant guilty of illegal possession of shabu and sentencing him to life
    imprisonment and a fine of ₱500,000.00.
     The Regional Trial Court convicted the appellant of illegal possession of shabu
    and acquitted his co-accused, Godofredo Siochi, on the ground of reasonable
    doubt.
    ISSUES OF THE CASE
     Whether the warrantless arrest of the appellant was valid.
     Whether the prosecution was able to establish the corpus delicti of the crime
    charged.
    ARGUMENTS OF PETITIONERS
     The appellant argued that his warrantless arrest was illegal since he was not
    committing any crime when the police arrested him. He also claimed that the
    police did not mark and photograph the seized items, and that there was a
    broken chain of custody over the confiscated drugs.
    ARGUMENTS OF RESPONDENTS
     The OSG countered that the testimony of PO3 Corbe was clear and convincing,
    and that the appellant’s arrest was valid. It also claimed that the seized shabu
    was admissible in evidence, and that there was no break in the chain of custody
    over the seized plastic bag containing shabu.
    HELD/RATIO:
     The Supreme Court held that the appellant’s warrantless arrest was unlawful, as
    there was no overt act indicative of a felonious enterprise that could be properly
    attributed to him to rouse suspicion in the mind of PO3 Corbe. The Court also
    held that the appellant’s act of running away was not a reliable indicator of guilt
    without other circumstances. Thus, the alleged plastic bag containing shabu
    seized from him was inadmissible in evidence, being the fruit of the poisonous
    tree.
     The Court also held that the appellant’s acquittal was in order due to the
    prosecution’s failure to establish the evidence of the corpus delicti with moral
    certainty. The Court noted the various lapses committed by the police in the
    handling, safekeeping and custody over the seized drug, such as the failure to
    mark, inventory and photograph the seized items, and the failure to comply with
    Section 21, Article II of R.A. No. 9165 and the chain of custody requirement. The
    Court ruled that these lapses tainted the integrity and evidentiary value of the
    confiscated shabu, and generated serious uncertainty about the identity of the
    seized items that the prosecution presented in evidence.
    DISPOSITION: The Supreme Court reversed and set aside the decision of the Court of
    Appeals and acquitted the appellant for failure of the prosecution to prove his guilt
    beyond reasonable doubt. He was ordered to be released from detention unless he was
    otherwise legally confined for another cause.

    You might also like