2016 January

(1)

Pedro Ladines Vs. People of the Philippines and Edwin De Ramon

G.R. No. 167333. January 11, 2016
Ponente: Bersamin, J.:

Indeterminate Sentence Law

To impose the highest within a period of the imposable penalty without specifying
the justification for doing so is an error on the part of the trial court that should be
corrected on appeal. By not specifying the justification for imposing the ceiling
period of the imposable penalty, the fixing of the indeterminate sentence became
arbitrary, or whimsical, or capricious. In the absence of the specification, the
maximum of the indeterminate sentenceshould be the lowest of theperiod.
(2)

Napoleon D. Senit Vs. People of the Philippines

G.R. No. 192914. January 11, 2016
Ponente: Reyes, J.:

Trial in Absentia
The holding of trial in absentia is authorized under Section 14(2), Article III of the
1987 Constitution which provides that after arraignment, trial may proceed
notwithstanding the absence of the accused provided that he has been duly notified
and his failure to appear is unjustifiable.
(3)

Erwin Libo-on Dela Cruz Vs. People of the Philippines

G.R. No. 209387. January 11, 2016
Ponente: Leonen, J.:

Illegal Possession of Firearms

While mere possession, without criminal intent, is sufficient to convict a person
for illegal possession of a firearm, it must still be shown that there was animus
possidendi or an intent to possess on the part of the accused. In the absence of
animus possidendi, the possessor of a firearm incurs no criminal liability.
Period of Preventive Imprisonment Deducted from Term of Imprisonment
Petitioners detention is relevant in determining whether he has already served
more than the penalty imposed upon him by the trial court as modified by this
court, or whether he is qualified to the credit of his preventive imprisonment with
his service of sentence.
(4)
People of the Philippines Vs. Fernando Ranche Havana a.k.a. Fenando
Ranche Abana
G.R. No. 198450. January 11, 2016
Ponente: Del Castillo, J.:
Chain of Custody Rule in Drugs Cases
Statutory rules on preserving the chain of custody of confiscated prohibited drugs
and related items are designed to ensure the integrity and reliability of the
evidence to be presented against the accused. Their observance is the key to the
successful prosecution -of illegal possession or illegal sale of dangerous drugs.

(5)
Enrique G. De Leon Vs. People of the Philippines and SPO3 Pedrito L.
Leonardo
G.R. No. 212623. January 11, 2016
Ponente: Mendoza, J.:
Serious or Slight Oral Defamation
Whether the offense committed is serious or slight oral defamation, depends not
only upon the sense and grammatical meaning of the utterances but also upon the
special circumstances of the case, like the social standing or the advanced age of
the offended party
(6)
People of the Philippines Vs. Jerry Pepino y Rueras and Preciosa
Gomez y Campos
G.R. No. 174471. January 12, 2016
Ponente: Brion, J.:
Kidnapping Duration of Detention
If the victim of kidnapping and serious illegal detention is a minor, the duration of
his detention is immaterial. Likewise, if the victim is kidnapped and illegally
detained for the purpose of extorting ransom, the duration of his detention is also
of no moment and the crime is qualified and becomes punishable by death even if
none of the circumstances mentioned in paragraphs 1 to 4 of Article 267 is present.
(7)

Paz Cheng y Chu Vs. People of the Philippines

G.R. No. 174113. January 13, 2016
Ponente: Perlas Bernabe, J.:

Estafa
The essence of this kind of [E]stafa is the appropriation or conversion of money
or property received to the prejudice of the entity to whom a return should be
madeIn proving the element of conversion or misappropriation, a legal
presumption of misappropriation arises when the accused fails to deliver the
proceeds of the sale or to return the items to be sold and fails to give an account of
their whereabouts.
(8)

People of the Philippines Vs. Ronaldo Casacop y Amil

G.R. No. 210454. January 13, 2016
Ponente: Perez, J.:

The dangerous drug itself, the shabu in this case, constitutes the very corpus delicti
of the offense and in sustaining a conviction under R.A. No. 9165, the identity and
integrity of the corpus delicti must definitely be shown to have been preserved.
(9)

People of the Philippines Vs. Manuel Macal y Bolasco

G.R. No. 211062. January 13, 2016
Ponente: Perez, J.:

Defense of Accident
In raising the defense of accident, the accused-appellant had the inescapable
burden of proving, by clear and convincing evidence, of accidental infliction of
injuries on the victim.
Absence of Mitigating and Aggravating Circumstances in Penalty Imposed

In the absence of mitigating and aggravating circumstances in the commission of

the crime, the lesser penalty shall be imposed.
(10)

Howard C. Lescano aka "Tisoy" Vs. People of the Philippines

G.R. No. 214490. January 13, 2016
Ponente: Leonen, J.:

Section 21 of the Comprehensive Dangerous Drugs Act of 2002

Compliance with Section 21s requirements is critical. Non-compliance is
tantamount to failure in establishing identity ofcorpus delicti, an essential element
of the offenses of illegal sale and illegal possession of dangerous drugs. By failing
to establish an element of these offenses, non-compliance will, thus, engender the
acquittal of an accused.
(11)

People of the Philippines Vs. Anita Miranda y Beltran

G.R. No. 205639. January 18, 2016
Ponente: Peralta, J.:

It is material in every prosecution for the illegal sale of a prohibited drug that the
drug, which is the corpus delicti, be presented as evidence in court. Hence, the
identity of the prohibited drug must be established without any doubt. Even more
than this, what must also be established is the fact that the substance bought
during the buy-bust operation is the same substance offered in court as exhibit.
The chain of custody requirement performs this function in that it ensures that
unnecessary doubts concerning the identity of the evidence are removed.
(12)

People of the Philippines Vs. Juan Asislo y Matio

G.R. No. 206224. January 18, 2016
Ponente: Peralta, J.:

The essential element of the charge of illegal transportation of dangerous drugs is

the movement of the dangerous drug from one place to another. There is no
definitive moment when an accused "transports" a prohibited drug. When the
circumstances establish the purpose of an accused to transport and the fact of
transportation itself, there should be no question as to the perpetration of the
criminal act.
(13)

People of the Philippines Vs. Glen Piad y Bory, et al.

G.R. No. 213607. January 25, 2016
Ponente: Mendoza, J.:

Chain of Custody
Evidently, the law requires "substantial" and not necessarily "perfect adherence" as
long as it can be proven that the integrity and the evidentiary value of the seized
items were preserved as the same would be utilized in the determination of the
guilt or innocence of the accused.

2016 February

(1)

Guilbemer Franco Vs. People of the Philippines

G.R. No. 191185. February 1, 2016
Ponente: Reyes, J.:

Burden of Proof
The Constitution presumes a person innocent until proven guilty by proof beyond
reasonable doubt. The prosecution cannot be allowed to draw strength from the
weakness of the defense's evidence for it has the onus probandi in establishing the
guilt of the accused -ei incumbit probatio qui dicit, non que negat -he who asserts,
not he who denies, must prove.
(2)

People of the Philippines Vs. Lee Quijano Enad

G.R. No. 205764. February 3, 2016
Ponente: Perlata, J.:

Burden of Proof for Chain of Custody in Drugs Cases

The prosecution must establish the unbroken chain of custody of the seized item.
(3)

Roberto Palo y De Gula Vs. People of the Philippines

G.R. No. 192075. February 10, 2016
Ponente: Perez, J.:

The fact that the apprehending officer marked the plastic sachet at the police
station, and not at the place of seizure, did not compromise the integrity of the
seized item. Jurisprudence has declared that "marking upon immediate
confiscation" contemplates even marking done at the nearest police station or
office of the apprehending team.
(4)

The People of the Philippines Vs. Cristy Dimaano y Tipdas

G.R. No. 174481. February 10, 2016
Ponente: Leonen, J.:

Inconsistencies in the testimonies of prosecution witnesses in cases involving

violations of the Comprehensive Dangerous Drugs Act may be excused so long as
the identity of the dangerous drugs is proved beyond reasonable doubt and the
chain of custody is established with moral certainty.
(5)

People of the Philippines Vs. Reman Sariego

G.R. No. 203322. February 24, 2016
Ponente: Peralta, J.:

It is the concurrence of both the minority of the victim and her relationship with
the offender that will be considered as a special qualifying circumstance, raising
the penalty to the supreme penalty of death.
(6)

Ofelia C. Caunan Vs. People of the Philippines and the Sandiganbayan

G.R. No. 183529. February 24, 2016
Ponente: Reyes, J.:

On Bad faith and Manifest Partiality in Corrupt practices

Partiality is synonymous with bias which excites a disposition to see and

report matters as they are wished for rather than as they are. Bad faith does not
simply connote bad judgment or negligence; it imputes a dishonest purpose or
some moral obliquity and conscious doing of a wrong; a breach of sworn duty
through some motive or intent or ill will; it partakes of the nature of fraud.
2016 March
(1)

Solomon Verdadero y Galera Vs. People of the Philippines

G.R. No. 216021. March 2, 2016
Ponente: Mendoza, J.:

Insanity as a Defense
In order to ascertain a persons mental condition at the time of the act, it is
permissible to receive evidence of his mental condition during a reasonable period
before and after. Direct testimony is not required nor are specific acts of
disagreement essential to establish insanity as a defense.
(2)

People of the Philippines Vs. Edgardo Perez y Alavado

G.R. No. 208071. March 9, 2016
Ponente: Peralta, J.:

Information charging an accused with the crime of rape qualified by relationship

must succinctly state said accused is a relative within the third civil degree by
consanguinity or affinity.
(3)

Jessica Lucila G. Reyes Vs. The Honorable Ombudsman/Jessica Lucila

G. Reyes Vs. The Honorable Sandiganbayan and People of the
Philippines/Janet Lim Napoles Vs. Conchita Carpio Morales in her
capacity as Ombudsman, People of the Philippines and
Sandiganbayan/Jo Christine Napoles and James Christopher Napoles
Vs. Conchita Carpio Morales in her capacity as Ombudsman, People of
the Philippines and Sandiganbayan/John Raymund De Asis Vs.
Conchita Carpio Morales in her capacity as Ombudsman, People of the
Philippines and Sandiganbayan
G.R. Nos. 212593-94/G.R. Nos. 213163-78/G.R. Nos. 213540-41/G.R.
Nos. 213542-43/G.R. Nos. 215880-94/G.R. Nos. 213475-76. March 15,
2016
Ponente: Perlas Bernabe, J.:

A Private Individual may be made answerable for the crimes of plunder

While the primary offender in the aforesaid crimes are public officers, private
individuals may also be held liable for the same if they are found to have
conspired with said officers in committing the same. This proceeds from the
fundamental principle that in cases of conspiracy, the act of one is the act of all.