G.R. No. 220486 PEOPLE v.

CORPUZ
DOCTRINE: There is treachery when the offender commits any of the crimes against persons, employing
means, methods, or forms in the execution of the crime that tend directly and especially to ensure its execution
without risk to himself arising from the defense which the offended party might make.
CASE NATURE: This appeal assails the Decision of the Court of Appeals affirming appellant's conviction for
murder with modification of the monetary awards.
FACTS: At afternoon, Jerry, while about to ride his motorcycle, he was flagged down by Porfirio Corpuz, to
confront him about a dog. Jerry's wife Ofelia saw the altercation and she got worried. She saw Jerry falling to the
ground and Porfirio immediately going on top of him. Porfirio's brother, appellant appeared with a gun in hand.
He walked up to Jerry and shot the latter twice. Jerry died even before they got to the hospital. Meanwhile,
appellant, still holding his gun, walked away into the fields.
The trial court rendered a verdict of conviction. CA affirmed the conviction.
ISSUE: Whether or not the Court of Appeals err in affirming appellant's conviction for murder.
HELD: The Court held yes. The appeal utterly lacked merit.
Murder requires the following elements: (1) a person was killed; (2) the accused killed him or her; (3) the killing
was attended by any of the qualifying circumstances mentioned in Article 248 of the Revised Penal Code; and
(4) the killing is not parricide or infanticide.
The prosecution witnesses positively identified appellant as the person who walked toward the victim while the
latter was pinned to the ground by appellant's brother. Then, without any warning, appellant suddenly, swiftly
and unexpectedly shot the victim not once but twice. Appellant's act of shooting the victim while the latter was
pinned down by another effectively denied the victim the chance to defend himself or to retaliate against his
perpetrators. Further, the victim was shot twice, as if making sure he would be mortally injured or killed.
The victim's slaying was more spontaneous than planned. Eyewitnesses testified that when appellant saw the
victim pinned on the ground by Porfirio, he walked to them and shot Jerry twice. Hence, there was no showing
that the killing was plotted or that there was enough time for appellant to reflect on the consequences of killing
his victim before actually carrying it out.
Therefore, the appellant was guilty of the crime of murder
G.R. No. 225789 PEOPLE v. DELA TORRE
DOCTRINE: Section 21(a) of the Implementing Rules and Regulations (IRR) requires that the inventory be
conducted immediately after seizure and confiscation, thus it must be done at the place of the arrest.
CASE NATURE: This appeal assails the Decision of the Court of Appeals affirming appellant's conviction for
violation of Section 5, Article II of Republic Act No. 9165.
FACTS: Acting on the report of a confidential informant, PCI Lopez formed and dispatched a buy-bust team
thereto. Around 5 o'clock in the afternoon, the team arrived. The confidential informant introduced PO3
Calimlim to appellant as interested buyer. Appellant took out a plastic sachet containing white crystalline
substance and handed it to PO3 Calimlim; in turn, PO3 Calimlim gave appellant three (3) marked Php100.00
bills. After the sale had been consummated, the team closed in and arrested appellant.
Seized from appellant were the marked money and the plastic sachet containing white crystalline substance. PO3
Calimlim immediately marked the plastic sachet with his initials "ALC-1." Thereafter, they brought appellant and
the seized items to the Magsaysay Barangay Hall before Barangay Kagawads Junvee Mislang and Eddie Manaois.
In their presence, PO3 Calimlim and SPO1 Ferrer inventoried the seized items. PNP Crime Laboratory Forensic
chemist found the item positive for methamphetamine hydrochloride.
The trial court found that the prosecution established beyond reasonable doubt that appellant was caught in
flagrante delicto selling shabu to PO3 Calimlim.
CA affirmed the ruling of the Trial Court, holding that inventory of the seized item at the Barangay Hall rather
than the place of arrest is an acceptable deviation for the prosecution proved the uninterrupted chain of custody
over the seized drug items.
ISSUE: Whether or not the chain of custody rule was deviated during the buy-bust operation.
HELD: The Court held yes.
The Implementing Rules and Regulations of RA 9165 commands the apprehending officer/team, immediately
after seizure and confiscation, to physically inventory and photograph the drugs in the presence of the accused,
or his/her representative or counsel, a representative from the media and the DOJ, and any elected public official
who shall be required to sign the copies of the inventory and be given a copy thereof: Provided, that the physical
inventory and photograph shall be conducted at the place where the search warrant is served; or at the nearest
police station or at the nearest office of the apprehending officer/team, whichever is practicable, in case of
warrantless seizures.
The arresting officers' testimonies bear how the chain of custody here had been breached in several instances.
First, the inventory was conducted at the barangay hall, without any explanation as to the distance from the
nearest police station or nearest office of the apprehending team. The only explanation given was "to avoid any
commotion or any untoward incident" which to the Court, hardly justifies such deviation. Second, PO3 Calimlim
and SPO1 Ferrer both testified that there was neither a representative from the media nor from the DOJ during
the conduct of the post-operation procedures. No explanation was given for their absence. Finally, the
photograph requirement was not complied with at all.
Indeed, the repeated breach of the chain of custody rule here had cast serious uncertainty on the identity and
integrity of the corpus delicti. The metaphorical chain did not link at all, albeit it unjustly restrained petitioner's
right to liberty. Verily, therefore, a verdict of acquittal is in order.
G.R. No. 247558 PEOPLE v. QUIJANO
DOCTRINE: In possession of illicit drugs cases, ownership is inconsequential. Mere possession of the illicit
drugs is malum prohibitum and the burden of proof is upon the accused to prove that they have a permit or
clearance to possess the prohibited drugs.
CASE NATURE: This appeal assails the Decision of the CA, finding appellant guilty of illegal possession of
dangerous drugs under Section 11, Article II of Republic Act No. 9165.
FACTS: JO2 Arthur Briones, a jail officer assigned at the BJMP Manila, noticed Marivic Tulipat (a regular visitor
at the city jail) receiving a light violet bag from someone inside the city jail bakery. He became suspicious and
called her attention. Before she hesitantly approached him, she handed the bag to appellant Allan Quijano y
Sanding. This prompted him to also summon appellant who, just like Tulipat, appeared hesitant. He then asked
appellant about the contents of the bag. Instead of responding, however, appellant turned to Tulipat and tried to
give it back to her. He grabbed the bag and opened it, where he saw another blue bag with a transparent bag
containing white crystalline substance. He immediately arrested both. Tulipat attempted to escape but was
eventually caught at the main gate of the city jail.
The seized items were marked, inventoried, and photographed inside the Manila City Jail. Tulipat, appellant,
JO3 Jose Rodzon Antonio, Senior Assistant City Prosecutor, a Barangay Kagawad and a Police Inspector were
all present during the procedure. They brought these items and the referral letter signed by City Jail Warden
Superintendent to the PDEA at 2020H. The same was received by the Forensic Chemist, who later certified that
the seized item yielded positive results for methamphetamine hydrochloride, a dangerous drug.
The Trial Court found the accused guilty. CA affirmed the decision.
ISSUE: Whether or not the CA erred in affirming appellant's conviction for illegal possession of dangerous
drugs.
HELD: The Court held no. Both the trial court and the Court of Appeals correctly found that the prosecution
was able to sufficiently establish all the elements of illegal possession of dangerous drugs.
For a successful prosecution of an offense for illegal possession of dangerous drugs, the prosecution must
establish the following elements: (a) the accused was in possession of an item or object identified as a prohibited
drug; (b) such possession was not authorized by law; and (c) the accused freely and consciously possessed the
said drug. This crime is mala prohibita, as such, criminal intent is not an essential element. The accused cannot
avoid conviction if his right to exercise control and dominion over the place where the contraband is located, is
shared with another
Here, appellant's actuations are likewise unnatural and contrary to man's common experience. His actuations in
fact indicate a guilty mind. During the commotion inside the city jail involving Tulipat and the bag in question,
Tulipat suddenly handed the bag to appellant who readily and unquestionably accepted it. Under normal
circumstances, appellant should have already become suspicious when he saw and heard JO2 Briones calling for
Tulipat because of the bag she was holding at that time. In fact, appellant himself said Tulipat's possession of the
bag already caused a commotion inside the city jail. In any event, when JO2 Briones also called for appellant
himself, like Tulipat, the latter hesitated and even tried to pass on the bag back to Tulipat who refused to accept
it. And when appellant finally came face to face with JO2 Briones, appellant did not immediately surrender the
bag to the former nor denied his ownership of the bag or knowledge of the shabu found inside. Even during the
investigation, appellant was not shown to have interposed any such disclaimer. Surely, these circumstances
altogether negate appellant's pretense of lack of animus possidendi.
In sum, the trial Court and the Court of Appeals did not err in finding appellant guilty of violation of Section 11,
Article II of RA 9165 as amended by RA 10640, otherwise known as the Comprehensive Dangerous Drugs Act of
2002.
G.R No. 248130 GANAL v. PEOPLE
DOCTRINE: To successfully claim self-defense, an accused must satisfactorily prove these elements: (1)
unlawful aggression; (2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of
sufficient provocation on the part of the person defending himself or herself.
CASE NATURE: This Petition for Review assails the Decision, affirming the trial court's conviction of petitioner
for homicide but mitigated by passion and obfuscation and voluntary surrender.
FACTS: Castillo and Ubina were drinking Ginebra Kuatro Cantos in petitioner's house when Angelo Follante,
attempted to throw stones to them and when the petitioner refused to let him join them. Petitioner and his
companions resumed their drinking when Angelo left. Thirty minutes later, stones were hurled at the roofs of
the adjacent houses of petitioner and his father, Ganal, Sr. He went out to check and saw Angelo together with
his uncle Julwin - the deceased. Ganal, Sr. tried to pacify the two, but they still proceed to advance. Julwin, then
holding palm-sized stones in both hands, managed to push open the gate. As Ganal, Sr. tried to pull back the
gate, Julwin hit him with a stone in the chest. Ganal, Sr. fell on the plant box made of hollow blocks and passed
out.
Petitioner saw what happened. Julwin, who had a knife tucked in his waistband and holding two (2) stones,
advanced towards him. Petitioner got his gun and fired a warning shot into the air. Angelo ran away but Julwin
continued advancing towards him. When Julwin was about two to three meters away, petitioner thought that the
victim was intent on killing him. Petitioner fired at Julwin, who in turn, pointed a finger at him, threatening to
kill everyone inside the house. Afraid that Julwin would make good on his threat, petitioner fired all the rounds
in his gun. Julwin fell within a meter from petitioner's door. Petitioner called the Baggao Police Station and
committed to surrender himself.
RTC held the accused guilty to the crime of homicide with passion and obfuscation and voluntary surrender as
mitigating circumstances. CA affirmed the ruling
ISSUE: Whether or not the killing would be justifiable as self-defense.
HELD: The Court held yes.
To successfully claim self-defense, an accused must satisfactorily prove these elements: (1) unlawful aggression;
(2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of sufficient provocation on
the part of the person defending himself or herself.
Here, the aggression from the victim puts in real peril the life or personal safety of Ganal Sr. The attendant
circumstances speak of the real and palpable peril posed by Julwin on the lives and limbs of petitioner and his
father. The peril was certainly far from fiction or imaginary. Lack of sufficient provocation on the part of the
person defending himself or herself, is also present here. In fact, both the prosecution and defense were one in
saying that it was Julwin who went to petitioner's house and instigated the incident. The Court also held that
reasonable necessity means to prevent and repel the aggression was also present, as opposed to the RTC and CA
ruling. Faced by a determined and prepared foe, petitioner, who was simply drinking with his friends, suddenly
found himself in a situation where he had to defend himself and his family from serious harm or even death.
Notably, petitioner first tried to simply scare off Julwin by firing a warning shot. Julwin was unfazed and still
continued to advance toward him with malevolent intent. And even after petitioner shot Julwin, the latter did
not even falter but instead threatened to kill petitioner and his family. Petitioner must have thought that his
actions were so futile because Julwin was still standing there and shouting threats. Petitioner, at that instant,
must have felt he had to end it once and for all - kill or be killed. So, he shot Julwin four more times until the
latter fell just a meter away from him.
Indeed, petitioner must be exonerated for he had acted only in self-defense.
G.R. No. 248929 PEOPLE v. DELOS SANTOS
DOCTRINE: Parricide is committed when (1) a person is killed; (2) the accused is the killer; and (3) the
deceased is either the legitimate spouse of the accused, or any legitimate or illegitimate parent, child, ascendant
or descendant of the accused.
CASE NATURE: This appeal assails the Decision of the Court of Appeals which affirmed the trial court's verdict
of conviction against Paulino Delos Santos, Jr. alias "Skylab" (appellant) for parricide.
FACTS: On May 8, 2011, around 11:30 in the evening, while Michael, Diego, Dante, Hennie and Marcos Delos
Santos were hanging out, appellant, appeared to be intoxicated and armed with a knife, suddenly arrived. He
instantly engaged in a heated verbal argument with his brother Marcos. This awakened appellant's father
Paulino, Sr.. He then prodded appellant to leave but the latter refused. Appellant adamantly warned his father
not to interfere and challenged him to a fight. While they were pushing each other, appellant suddenly stabbed
Paulino, Sr. in the upper left side of the chest, causing the latter to fall on the ground. Thereupon, appellant
immediately fled. Paulino, Sr. died even before he was brought to the hospital.
During the trial, Michael positively identified appellant as the person who stabbed and killed his father Paulino,
Sr. The Trial Court found the appellant guilty of parricide. CA affirmed the ruling.
ISSUE: Whether or not the Court of Appeals err in affirming appellant's conviction for parricide
HELD: The Court held no. SC affirmed the ruling of RTC and CA.
Article 246 of the Revised Penal Code defines and penalizes parricide, viz.: Article 246. Parricide. - Any person
who shall kill his father, mother, or child, whether legitimate or illegitimate, or any of his ascendants, or
descendants, or his spouse, shall be guilty of parricide and shall be punished by the penalty of reclusion perpetua
to death.
The presence of the third element here is undisputed. Appellant himself admitted and declared under oath that
the deceased Paulino, Sr. is his father. He also stipulated this fact during the pre-trial. As for the first and second
elements, Michael positively and categorically identified appellant as the person who killed his father, Paulino,
Sr. Michael narrated in detail the events that led to the killing of Paulino, Sr., from the time appellant arrived at
the scene, drunk and armed with a knife, up till appellant argued with his brother, warned his father not to
interfere, challenged his father to a fight, pushed him, and stabbed him in the upper left chest, causing the latter
to fall on the ground and die. The Court weighed importance on the consistency of the witness in testifying on
the essential elements of the crime and his positive and categorical identification of the accused as the offender,
considering was not shown to have been impelled by any ill will to falsely impute such heinous crime as parricide
on appellant. His testimony, therefore, is worthy of belief and credence.
Therefore, the accused was guilty beyond reasonable doubt of the crime of parricide.