PEOPLE V. MANANSALA Y ALFARO [G.R. No. 233104, September 2, 2020]

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PEOPLE V. MANANSALA Y ALFARO

G.R. No. 233104, September 2, 2020

SECOND DIVISION, HERNANDO J.

 

Murder, Treachery, Evident Premeditation, Ciscumstantial Evidence

DOCTRINE: Circumstantial evidence can be sufficient to support a conviction in the absence of direct evidence, as long as the circumstances proved form an unbroken chain leading to a fair and reasonable conclusion pointing to the accused as the perpetrator, to the exclusion of all others.

 

Manansala y Alfaro, was charged with murder for the killing Armando Ramos y Santos. The prosecution presented eyewitness testimonies, along with CCTV footage that showed a man resembling Manansala entering the victim's house, shooting him, and quickly leaving. The medical findings indicated that the gunshot wound was at the victim's back, which was fatal. They argued that treachery and evident premeditation were present. Manansala denied the charges, claiming he was in Bulacan during the incident.

RTC found accused guilty considering treachery and evident premeditation based on the altercation between the victim and Manansala before the incident. The Court of Appeals affirmed the RTC's decision, relying on the corroborated eyewitness testimonies and the CCTV footage, which clearly identified Manansala as the perpetrator.

 

Whether the appellant is guilty of murder and whether treachery and evident premeditation were present during the commission of the crime.

 

 YES. In this case, the death of the victim Ramos is undisputed. The court relied on circumstantial evidence, which sufficiently supported the finding that Manansala was the perpetrator of the crime. Circumstantial evidence, also known as indirect or presumptive evidence, refers to proof of collateral facts and circumstances whence the existence of the main fact may be inferred according to reason and common experience.

As to the qualifying circumstances, treachery was confirmed based on the sudden and unexpected attack from behind, as seen in eyewitness accounts and CCTV footage. However, the court concluded that the prosecution failed to satisfactorily prove the presence of evident premeditation. The essence of evident premeditation is that the execution of the criminal act must be preceded by cool thought and reflection. Evident premeditation must be based on external acts and must be evident, not merely suspected, indicating deliberate planning.

Nevertheless, the killing remains murder due to the presence of treachery.

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PEOPLE V. CATIG Y GENTERONI [G.R. No. 225729, March 11, 2020]

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PEOPLE V. CATIG Y GENTERONI

G.R. No. 225729, March 11, 2020

SECOND DIVISION, HERNANDO J.

 

Rape, Mental Retardation

 Doctrine: Any sexual encounter with a person diagnosed with mental retardation, even if the individual seemingly consents, is still considered non-consensual intercourse under the law due to their incapacity to provide informed and valid consent.

 

This involves an alleged incident of rape who was 15 years old at the time, has been diagnosed with moderate mental retardation, which affects her cognitive and decision-making abilities. The prosecution presented testimonies and evidence supporting their claim that the accused forcibly engaged in sexual intercourse with the victim against her will and consent. The defense, on the other hand, asserted that the sexual encounter was consensual and that the victim willingly participated in the act.

 

Whether the accused is guilty of rape under the RPC.

 

YES. The Supreme Court agreed that the sexual act was non-consensual and that the victim's mental retardation rendered her unable to give valid consent. The absence of valid consent is a crucial element in rape cases.

This case raised an essential issue concerning the victim's mental condition and her ability to provide consent. The Court recognized that persons with mental retardation may have limited cognitive capabilities and may not fully comprehend the consequences of their actions. As a result, any sexual encounter with a person diagnosed with mental retardation, even if the individual seemingly consents, is still considered non-consensual under the law due to their incapacity to provide informed and valid consent.

The ruling reinforced the principle that consent must be given freely and intelligently for any sexual act to be considered lawful.

 

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PEOPLE V. BALUYOT Y BIRANDA [G.R. No. 243390, October 5, 2020]

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PEOPLE V. BALUYOT Y BIRANDA

G.R. No. 243390, October 5, 2020

SECOND DIVISION, HERNANDO J.

 

RA 9165, Illegal Sale, Chain of Custody Rule

Doctrine: Strict compliance with the chain of custody rule is crucial to preserve the integrity of the evidence in drug-related cases. Failure to clearly establish the chain of custody from the time of seizure to the time of presentation in court, will raised doubts about the integrity and identity of the evidence, which will warrant acquittal.

 

Alex Baluyot was charged with 2 separate information relating to violation of dangerous drugs law based on a buy-bust operation conducted by PDEA officers. The prosecution presented evidence of the sale and positive drug test results. The RTC found him guilty of illegal sale. However, the RTC acquitted him of illegal possession of dangerous drugs due to uncertainty in establishing the identity of the seized specimens. CA denied the appeal but modified the ruling to make Alex ineligible for parole.

Alex now appeals to the Supreme Court, arguing that the chain of custody rule was not followed, and the testimonies of the PDEA officers were inconsistent. The OSG, maintains that the integrity of the seized drugs was preserved, and the testimonies of the prosecution witnesses were credible. The case is now before the Supreme Court for review.

 

Whether or not Alex is guilty of Illegal Sale of Dangerous Drugs.

 

NO. The appeal of Alex Baluyot is granted, and he is acquitted of the charge of violating Section 5, Article II of RA 9165 (Illegal Sale of Dangerous Drugs). The court found that the prosecution successfully established the elements of the crime through testimonies and evidence. However, there was a failure to properly observe the chain of custody rule during the operation, as only two witnesses were present during the marking of the seized items instead of the required three. The absence of a representative from the DOJ was not justified, and the prosecution failed to show justifiable grounds for non-compliance with the three-witness requirement. This lapse compromised the integrity of the seized items, creating reasonable doubt on Alex's guilt. Therefore, he is acquitted.

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PEOPLE V. ARELLAGA Y SABADO [G.R. No. 231769, August 24, 2020]

 

PEOPLE V. ARELLAGA Y SABADO

G.R. No. 231769, August 24, 2020

SECOND DIVISION, HERNANDO J.

 

RA 9165, Illegal Sale, Chain of Custody Rule, Illegal Possession

Doctrine: Failure to explain the absence of the required three-witness rule or justify the deviation from the mandatory procedure outlined in Section 21 Article II of RA 9165 will create a reasonable doubt on the identity of the seized drugs, which will results to acquittal; as the integrity of the corpus delicti had been compromised.

 

Sabado was charged with illegal sale and illegal possession of dangerous drugs. The prosecution's version was supported by the testimonies of two police officers, PO2 Reynold Reyes and PO3 Niño Baladjay, who conducted the buy-bust operation. They testified that the appellant sold a sachet of shabu to the poseur buyer, and upon his arrest, three more sachets were found in his possession.

On the other hand, the defense presented the appellant's testimony and his stepdaughter, Nica Andrea Cruz's account of the incident. They claimed that the police officers unlawfully entered their house, conducted a warrantless search, and allegedly stole personal items. During the trial, the defense raised issues concerning the chain of custody rule and the integrity of the evidence presented by the prosecution.

 

Whether the prosecution has sufficiently complied with the chain of custody rule for the seized drugs.

 

NO. The Supreme Court emphasize the importance of chain of custody rule to preserve the integrity and identity of the seized drugs, as they constitute the corpus delicti of the offense. The chain of custody rule requires the presence of three witnesses during the inventory and photographing of the confiscated drugs, as stated in Section 21 of RA 9165.

However, the prosecution in this case failed to clearly establish compliance with the requirements of Section 21, particularly the three-witness rule. There were no three witnesses during the inventory and photograph taking of the drugs, and no justifiable grounds were shown for their absence. The Court has held that the presence of the required number of witnesses at the time of the apprehension and inventory, is mandatory. Their presence would provide certainty about the source, identity, and integrity of the seized drugs and refute any defense of frame-up. However, the buy-bust team in this case only had one witness which is insufficient under Section 21.

Due to the prosecution's failure to prove the guilt of the appellant beyond reasonable doubt and their inability to comply with the necessary procedures under RA 9165, the Court acquitted Sabado.

 

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VALDES V. LA COLINA DEVELOPMENT CORP. [G.R. No. 208140, July 12, 2021]

 

VALDES V. LA COLINA DEVELOPMENT CORP.

G.R. No. 208140, July 12, 2021

THIRD DIVISION, HERNANDO J.

 

Obligations and Contracts; Sales; Joint Venture; Novation; Causal Fraud; Rescission 

Doctrine: The Supreme Court's ruling in this case reaffirms the principle that parties should act in good faith during contract negotiations and emphasizes the consequences of fraudulent misrepresentations and material breaches in joint venture agreements.

 

In 2015, Mr. Miguel Valdes and La Colina Development Corporation entered into a joint venture agreement to develop a commercial complex in an urban area. Mr. Valdes was responsible for architectural design and funding, while the corporation was tasked with securing permits. Disputes arose due to delays caused by the corporation's failure to promptly secure permits and its fraudulent misrepresentations about financial capabilities. Mr. Valdes filed a case seeking rescission of the joint venture agreement based on causal fraud and breach of contract. The trial court ruled in his favor, ordering the agreement's rescission and reimbursement of incurred costs.

La Colina Development Corporation appealed the decision to the Court of Appeals but was denied. Unsatisfied, they elevated the case to the Supreme Court for further review.

 

Whether the trial court correctly rescinded the joint venture agreement based on causal fraud?

 

YES. The Supreme Court affirmed the decision of the trial court and upheld the rescission of the joint venture agreement. The court reasoned that La Colina Development Corporation's fraudulent misrepresentations were instrumental in inducing Mr. Valdes to enter into the contract. The corporation's failure to secure necessary permits and licenses further supported the rescission as it amounted to a substantial breach of their contractual obligations.

Regarding the reimbursement of costs, the court held that Mr. Valdes was entitled to be restored to his original position before the fraudulent inducement. Thus, the reimbursement of costs incurred by Mr. Valdes was deemed proper and just.

The court also clarified that rescission is a proper remedy for cases involving causal fraud and material breaches of contract. Rescission allows parties to be released from their obligations, rendering the contract voidable from the beginning.

 

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SPOUSES PONCE V. ALDANESE [G.R. No. 216587, August 4, 2021]

 

SPOUSES PONCE V. ALDANESE

G.R. No. 216587, August 4, 2021

SECOND DIVISION, HERNANDO J.

 

Property; Possession; Ownership

Principle: The case emphasizes the importance of presenting substantial evidence to establish ownership and possession rights over disputed land. It also serves as a reminder that mere encroachment or possession of land is not enough to claim ownership, and the true owner should be determined based on valid evidence and legal rights.

 

Jesus Aldanese inherited the land known as Lot No. 6890 located in Sibonga, Cebu from his father and diligently paid its real property taxes. In 1996, he discovered that the Spouses Ponce encroached upon his land. Jesus demanded that they vacate the land, but the Spouses Ponce refused, claiming that Lot No. 6890 was part of the land they bought from Jesus' brother, Teodoro Aldanese, Jr.

Jesus denied the sale and filed a complaint for recovery of possession and damages. The RTC ruled in his favor of Jesus, declaring him as the absolute owner and possessor of Lot No. 6890. The Spouses Ponce appealed, arguing that the complaint should have been dismissed on grounds of prescription and that Jesus failed to sufficiently prove his ownership over the subject land.

 

Whether Jesus Aldanese has sufficiently proven his ownership and entitlement to possession of Lot No. 6890, despite the Spouses Ponce's claim of purchasing the land from his brother.

 

YES. The Court upheld Jesus' claim of ownership and possession, rejecting the Spouses Ponce's contention that they acquired the land through a valid purchase from Teodoro Aldanese, Jr.

The Supreme Court, upon reviewing the case, focused on determining the true ownership and possession of Lot No. 6890. Jesus presented tax declarations and certificates indicating his possession and ownership of the land. The Spouses Ponce failed to present evidence of their own ownership, and their claim that Lot No. 6890 was included in the sale is contradicted by Teodoro Aldanese Jr.'s testimony.

The Court determined that the evidence sufficiently supported Jesus' ownership and established his right to possess Lot No. 6890. Jesus Aldanese, was recognized as lawful owner and entitling him to possession of the land. The petition by the Spouses Ponce was denied.

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HEIRS OF BAGAYGAY V. HEIRS OF PACIENTE [G.R. No. 212126, August 4, 2021]

 

HEIRS OF BAGAYGAY V. HEIRS OF PACIENTE

G.R. No. 212126, August 4, 2021

SECOND DIVISION, HERNANDO J.

Evidence; Original Document; Secondary Evidence; Land Titles and Deeds; Public Land Act; Laches

PRINCIPLE: Documentary evidence prevails over testimonial evidence. The doctrine of Secondary Evidence of a Lost Document allows parties to present substitute evidence when the original document is unavailable.

 

The case involves a dispute over the ownership of a parcel of land initially granted to Anastacio Paciente, Sr. under a homestead patent. Subsequently, Anastacio allegedly sold the land to his brother-in-law, Eliseo Bagaygay, who then subdivided it and obtained new titles.

Upon the deaths of Anastacio and Eliseo, their respective heirs entered into a legal battle over the land's ownership and possession. The heirs of Anastacio sought to nullify the Deed of Sale and the titles issued to Eliseo, claiming it was executed within the five-year prohibition period under the Public Land Act. On the other hand, the petitioners, heirs of Eliseo, claimed that the sale was valid, that the sale indeed happened in 1958, beyond the five-year prohibition period. They also presented the Marriage Contract of respondent Meregildo to prove that his wedding, for which the money from the sale was supposedly used, took place on June 8, 1958.

The trial court ruled in favor of Eliseo's heirs, but the Court of Appeals reversed it. The CA gave more weight to documentary evidence showing the Deed of Sale was executed within the prohibition period, declaring it void ab initio.

 

Whether the Deed of Sale executed by Anastacio in favor of Eliseo is valid.

 

NO. The Public Land Act's provisions played a significant role in determining the validity of the Deed of Sale. The Act prohibits certain land transactions within a specified period, and compliance with its provisions was crucial in validating the sale.

The Supreme Court ruled in favor of the heirs of Anastacio Paciente, Sr., confirming them as the rightful owners entitled to possess the land. The Court relied on the assessment of evidence, including the Deed of Sale and the land titles. As the original Deed of Sale was not available, the Court considered the Primary Entry Book from the Register of Deeds as secondary evidence, which served as prima facie evidence of the Deed of Sale's execution date. The entries in the official record were deemed credible evidence, leading to the finding that the Deed of Sale was executed within the prohibition period. Consequently, the Deed of Sale was deemed void ab initio. As a result, the heirs of Anastacio were declared as the rightful owners entitled to possession of the land.

The concept of laches was raised as a defense by the heirs of Eliseo Bagaygay but was not upheld by the Court, since laches does not apply to void ab initio contracts.

 

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