THE Case Brief: Del Castillo v People

WELFARE OF FEBRUARY 13, 2017 ⁄ JEFF REY

THE PEOPLE G.R. No. 185125 January 30, 2012

SHALL BE
THE Ruben Del Castillo

SUPREME vs.
LAW
People of the Philippines
a repository of my notes
from law school
Facts:

Pursuant to a confidential information that petitioner Del Castillo was

engaged in selling shabu, police officers headed by SPO3 Bienvenido
Home Masnayon, after conducting surveillance and test-buy operation at the
About the Blog; Disclaimer house of petitioner, secured a search warrant from the RTC. Upon arrival

Case Digests to the residence of Del Castillo to implement the search warrant, SPO3
Masnayon claimed that he saw petitioner run towards a small structure, a
Lectures and Notes
nipa hut, in front of his house. Masnayon chased him but to no avail,
Random Stuff
because he and his men were not familiar with the entrances and exits of
the place. They all went back to the residence of Del Castillo and requested
his men to get a barangay tanod and a few minutes thereafter, his men
returned with two barangay tanods who searched the house of petitioner
Search …
! including the nipa hut where the petitioner allegedly ran for cover. His men
who searched the residence of the petitioner found nothing, but one of the
barangay tanods was able to confiscate from the nipa hut several articles,
including four (4) plastic packs containing white crystalline substance.
Follow The Welfare Of the People Shall Be The Supreme Law 22

Thus, an information was filed against Del Castillo for violation of Section
16, Article III of R.A. 6425 and was found guilty by the RTC and affirmed by
the Court of Appeals. Petitioner filed with the Supreme Court the petition
RECENT POSTS for certiorari contending among others that CA erred in finding him guilty
beyond reasonable doubt of illegal possession of prohibited drugs, because
Case Brief: People vs. Go (April 3,
he could not be presumed to be in possession of the same just because they
2018)
were found inside the nipa hut.
Case Brief: People vs Morales
(March 26, 2018)
Issue:
Can petitioner Del Castillo be held liable for violation of Section 16, Article
III of R.A. 6425 by mere presumption that the petitioner has dominion and
control over the place where the shabu was found?
ARCHIVES

Held:
April 2018 (1)

March 2018 (3) No. While it is not necessary that the property to be searched or seized
should be owned by the person against whom the search warrant is issued,
February 2018 (6)
there must be sufficient showing that the property is under petitioner’s
January 2018 (17) control or possession. The records are void of any evidence to show that
petitioner owns the nipa hut in question nor was it established that he used
December 2017 (20)
the said structure as a shop. The RTC, as well as the CA, merely presumed
May 2017 (30) that petitioner used the said structure due to the presence of electricalFollow
April 2017 (3) materials, the petitioner being an electrician by profession.

February 2017 (11) The prosecution must prove that the petitioner had knowledge of the
existence and presence of the drugs in the place under his control and
January 2017 (25)
dominion and the character of the drugs. With the prosecution’s failure to
April 2015 (1)
prove that the nipa hut was under petitioner’s control and dominion, there
March 2015 (3) casts a reasonable doubt as to his guilt. In considering a criminal case, it is
critical to start with the law’s own starting perspective on the status of the
February 2015 (2)
accused — in all criminal prosecutions, he is presumed innocent of the
January 2015 (6) charge laid unless the contrary is proven beyond reasonable doubt. Proof
beyond reasonable doubt, or that quantum of proof sufficient to produce a
November 2014 (4)
moral certainty that would convince and satisfy the conscience of those
October 2014 (7)
who act in judgment, is indispensable to overcome the constitutional
September 2014 (1) presumption of innocence.

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November 2013 (19)

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Categories: Criminal Law, Remedial Law and Legal Ethics Tags: dangerous drugs act,
del castillo, presumption of innocence, proof beyond reasonable doubt, quantum of proof,
Follow ra 6425, rights of accused, test-buy operation

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