FIRST DIVISION
[G.R. No. 248057. June 16, 2021.]
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,vs. MARCELINO LONTOC y BAYAS * and SHEILA ** PARAS y PERIDO, accused-appellants.
NOTICE
Sirs/Mesdames :
Please take notice that the Court, First Division, issued a Resolution datedJune 16, 2021which reads as follows:
"G.R. No. 248057 (People of the Philippines, Plaintiff-Appelleev. Marcelino Lontoc y Bayasand SheilaParas y Perido, Accused-Appellants.) — This is an appeal 1 from the Decision 2 dated 16 March 2018 of the Court of Appeals (CA) in CA-G.R. CR-HC No. 08290. The CA affirmed with modifications the Decision 3 dated 19 October 2015, rendered by Branch 23, Regional Trial Court (RTC), Trece Martires City, in Criminal Case Nos. TMCR-420-12 and TMCR-421-12, finding herein accused-appellants Marcelino Lontoc y Bayas (accused-appellant Lontoc) and Sheila Paras y Perido (accused-appellant Paras) guilty beyond reasonable doubt of violation of Sections 11 and 5, respectively, of Article II, Republic Act No. (RA) 9165. 4
Antecedents
On 25 July 2012, accused-appellant Lontoc and accused-appellant Paras (accused-appellants, collectively) were respectively charged with violation of Sections 11 and 5, Article II of RA 9165 in separate Informations, the accusatory portions of which read:
Criminal Case No. TMCR-420-12
That on or about the 24th day of July 2012, in the Municipality of General Trias, Province of Cavite, Philippines, a place within the jurisdiction of this Honorable Court, the abovenamed accused, not being authorized by law, did, then and there willfully, unlawfully and feloniously have in his possession, control and custody ZERO POINT ZERO EIGHT (0.08) gram of Methamphetamine Hydrochloride, commonly known as "Shabu," a dangerous drug, in violation of the provisions of R.A. 9165, otherwise known as the Comprehensive Dangerous Drugs Act of 2002.
CONTRARY TO LAW.5
Criminal Case No. TMCR-421-12
That on or about the 24th day of July 2012, in the Municipality of General Trias, Province of Cavite, Philippines, a place within the jurisdiction of this Honorable Court, the above-named accused, not being authorized by law, did, then and there willfully, unlawfully and feloniously sell, distribute and deliver to a poseur-buyer ZERO POINT ZERO FOUR (0.04) gram of Methamphetamine Hydrochloride, commonly known as "Shabu", a dangerous drug, in violation of the provisions of Republic Act No. 9165, otherwise known as the Comprehensive Dangerous Drugs Act of 2002.
CONTRARY TO LAW.6
When arraigned, 7 accused-appellants pleaded not guilty to their respective charges. Pre-trial and trial on the merits ensued thereafter. 8
Version of the Prosecution
On the basis of a tip by an informant, Senior Police Officer 4 Jose Eusebio (SPO4 Eusebio) caused the conduct of a week-long surveillance of accused-appellants who were allegedly engaged in rampant selling of shabu in General Trias, Cavite. Once the tip was confirmed, he formed a buy-bust team led by Police Officer 1 Rogie Cayaga (PO1 Cayaga), who was assigned as the poseur-buyer, and Police Officer 3 Rady De Jesus (PO3 De Jesus), the back-up officer. 9
At about 4:00 p.m. in the afternoon of 24 July 2012, the buy-bust team, together with the informant, proceeded to the target area. Once there, the informant introduced PO1 Cayaga to appellant Paras, who was aboard a motorcycle driven by accused-appellant Lontoc. Immediately thereafter, PO1 Cayaga transacted with accused-appellant Paras. 10
Accused-appellant Paras took one (1) plastic sachet of suspected shabu, contained in a Clorets candy wrapper, which she then handed to PO1 Cayaga in exchange for the marked money worth Php300.00. Subsequently, PO1 Cayaga executed the pre-arranged signal and grabbed the arm of accused-appellant Paras to restrain her. Meanwhile, PO3 De Jesus rushed to the scene to assist PO1 Cayaga in arresting accused-appellants. He immediately frisked accused-appellant Lontoc, and was able to retrieve three (3) plastic sachets containing shabu which were hidden from the coin pocket of the latter. 11
PO3 De Jesus marked the three (3) plastic sachets with "MBL-1," "MBL-2," and "MBL-3 while PO1 Cayaga marked the sachet subject of the sale with "SPP." 12 Also, the buy-bust team brought accused-appellants to the barangay hall where the inventory 13 of the seized items were conducted by PO3 De Jesus and PO1 Cayuga in the presence of accused-appellants and a barangay councilor. 14 Then, they proceeded to the police station and turned over the seized items to the duty investigator, PO2 Jesse Soriano. Next, PO1 Cayaga brought the seized specimens to the crime laboratory, where they were received by Forensic Chemist, Police Senior Inspector Oliver Dechitan (PSI Dechitan), for examination. As per Chemistry Report No. D-397-12 15 dated 24 July 2012, the seized items were positive for Methamphetamine Hydrochloride, otherwise known as shabu. 16
During the trial on the merits, however, the parties dispensed with the testimony of PSI Dechitan after stipulating that the latter indeed received the specimens for examination, though he did not have knowledge of their origin. 17
Version of the Defense
Accused-appellants claimed that in the afternoon of 24 July 2012, they were resting inside the room of their house when men in civilian clothes, whom they later identified as police officers, destroyed their main door, and barged into their house. 18 The police officers proceeded to their room and searched the same, supposedly looking for illegal drugs. 19
As the police officers' search yielded nothing, they brought accused-appellants outside their room. Later, more police officers arrived, went inside accused-appellants' room, and carted away a portable DVD, speaker, and two (2) cellular phones. 20 The police officers then transported accused-appellants to the General Trias Police Station and forced them to sign a Certificate of Inventory. They subsequently falsely charged them with the herein offenses. 21
Ruling of the RTC
After trial on the merits, the RTC issued its ruling, convicting accused-appellants of their respective charges. The dispositive portion of the Joint Decision reads:
"WHEREFORE, finding the guilt of the accused beyond reasonable doubt, Marcelino Lontoc is meted the penalty of twelve (12) years and one (1) day to twenty (20) years of imprisonment and to pay a fine of five hundred thousand pesos ([Php]500,000.00) in Crim Case No. TMCR-420-12.
While accused Sheila Paras is meted the penalty of twenty (20) years and one (1) day to forty (40) years of imprisonment and to pay a fine of one million pesos ([Php]1,000,000.00) in Criminal Case No. TMCR-421-12.
SO ORDERED." 22
Aggrieved, accused-appellants filed an appeal. In addition, accused appellant Lontoc filed a Motion to Post Bail Pending Appeal 23 which the RTC granted in its Order 24 dated 23 November 2015. After accused-appellant Lontoc posted the appropriate appeal bond, the RTC ordered his release. 25
Ruling of the CA
In due time, the CA issued the now assailed Decision, affirming the conviction of accused-appellants but modifying the penalties imposed by the RTC. The dispositive portion of the CA's ruling reads:
WHEREFORE, premises considered, the instant Appeal is DENIED. The assailed Decision dated October 19, 2015 of the RTC Branch 23 of Trece Martires City in Criminal Case Nos. TMCR-420-12 and TMCR-421-12 finding accused-appellants Marcelino Lontoc y Rayas and Sheila Paras y Perido guilty beyond reasonable doubt of Violation of Sections 11 and 5 of Article II of R.A. No. 9165, respectively, is hereby AFFIRMED with MODIFICATIONS to the effect that accused-appellant Marcelino Lontoc y Rayas is sentenced to suffer imprisonment of twelve (12) years, one (1) day, as minimum, to twenty (20) years, as maximum, and to pay a fine of four hundred thousand pesos ([Php]400,000.00) in Criminal Case No. TMCR-420-12. Accused-appellant Sheila Paras y Perido is sentenced to suffer the penalty of life imprisonment and to pay a fine of one million pesos ([Php]1,000,000.00) in Criminal Case No. TMCR-421-12.
SO ORDERED.26
Issues
Accused-appellants filed an appeal before the Court. And now, the Court is confronted to settle the issues of 1) whether or not the arrest of accused-appellants were valid; and 2) whether or not the prosecution was able to establish beyond reasonable doubt the guilt of accused-appellants in this case.
Ruling of the Court
The appeal is granted.
With respect to the issue of the legality of arrest, the facts show that accused-appellants were supposedly caught in flagrante delicto during a buy-bust operation. It is an irrefragable holding of the Court that the arrest of an accused who sold drugs during a buy-bust operation is valid, as is a circumstance where a warrantless arrest is justified under Sec. 5 (a), Rule 113 of the Rules of Court. 27 Corollarily, when a buy-bust operation is legitimate, the concomitant bodily search conducted by the police officers would likewise be valid, and a warrant is likewise not needed to conduct it. 28 The illegal drug seized by the police officers cannot be considered fruits of the poisonous tree as the seizure thereof by the entrapment team falls under a search incidental to a lawful arrest under Sec. 13, Rule 126 of the Rules of Court. 29
Accused-appellants heavily dispute the police officers' version of the events and claim that they were victims of frame-up. However, the validity of their arrest can no longer be threshed out by this Court at this late a stage. It is long-settled that any question regarding its legality should have been raised prior to arraignment; otherwise, it is deemed waived. 30
Indeed, accused-appellants waived their right to question the legality of their arrests by entering a plea and actively participating in the trial of their cases. Be that as it may, the Court acquits them for failure of the prosecution to prove their guilt beyond reasonable doubt.
Proving the identity of the corpus
It is settled that when it comes to Illegal Sale of Dangerous Drugs, the prosecution must prove: (a) the identity of the buyer and the seller, the object, and the consideration; and (b) the delivery of the thing sold and the payment. In Illegal Possession of Dangerous Drugs, on the other hand, the prosecution must establish the following elements to warrant his conviction: (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. 31
Apart from the foregoing elements, case law instructs that in both instances, the identity of the prohibited drug must be established with moral certainty considering that the dangerous drug itself forms an integral part of the corpus delicti of the crime. 32 Conviction is on shaky grounds if there is lingering doubt on the identity of the drugs in question. 33 If the identity and integrity of the seized drugs are questionable at its inception, then, the manner in which they are subsequently handled becomes irrelevant as lingering doubt would always follow the corpus delicti. 34
To establish the corpus delicti, it is
Since the offenses charged against the accused-appellants were allegedly committed on 24 July 2012, the original provisions of Section 21 of RA 9165 and its IRR applies in this case. 35
The law mandates, inter alia, that the marking, physical inventory, and photography of the seized items be conducted immediately after seizure and confiscation of the same. The law further requires that the said inventory and photographing be done in the presence of the accused or the person from whom the items were seized, or his representative or counsel, as well as certain required witnesses, namely: (a) if prior to the amendment of R.A. 9165 by R.A. 10640, a representative from the media and the Department of Justice, and any elected public official; or (b) if after the amendment of R.A. 9165 by R.A. 10640, an elected public official and a representative of the National Prosecution Service or the media. 36
The marking and inventory were
Based on the testimonies of the PO3 De Jesus and PO1 Cayaga, the inventory of the confiscated items was done at the barangay hall. It bears pointing out, however, that RA 9165 restrictively enumerates the places where the inventory and photographing of the seized drug specimen can be done: (1) at the place of seizure; (2) at the nearest police station; or (3) at the nearest office of the apprehending officer/team, whichever is practicable. 37 Evidently, the list does not include a barangay hall as a permissible alternative place to conduct the inventory.
Moreover, the Court nevertheless cannot gloss over the ubiquitous absence of a statement as to where the taking of photographs took place, if ever there was. PO3 De Jesus merely testified as to the conduct of inventory at the barangay hall. However, neither he nor PO1 Cayaga confirmed whether an accompanying taking of photographs took place. While there were certainly photographs of the seized items appearing on record, there was the obvious absence of a photograph evidencing the actual conduct of inventory, let alone a picture of the persons who witnessed the same. Without these photographs, it cannot be discounted that the conduct of inventory may have been reduced by the police officers to a mere formality, instead of an essential requirement in proving the identity of the seized drugs, by merely filling out the Inventory/Receipt of Property Seized and had it immediately signed by the accused-appellants and the barangay Councilor.
Prescinding, the Court also does not fail to see the inconsistencies in the statements of PO1 Cayaga as to where he marked the item seized from appellant Paras. In his Sinumpaang Salaysay, PO1 Cayaga claimed that he marked the item immediately at the place of arrest. During his court testimony, however, he testified that he marked the plastic sachet at the barangay hall. 38 This inconsistency is a serious blow to the prosecution's case. To be sure, marking after seizure is the starting point in the custodial link, thus it is vital that the seized contraband are immediately marked because succeeding handlers of the specimen will use the markings as reference. 39 The failure to mark the seized item immediately upon seizure reveals a break in the very first link of the chain 40 and casts reasonable doubt on the authenticity of the corpus delicti. 41
The necessity for police officers to comply with the safeguards for the marking, conduct of the inventory and taking of photographs cannot be overemphasized. Any deviation from the standard procedure dismally compromises the integrity of the evidence, and the only reason for the courts to overlook the police officers neglect or disobedience is for the Prosecution to recognize the deviations, as well as to explain them in terms of their justifiable grounds, and to show that the integrity and evidentiary value of the evidence seized were nonetheless substantially preserved. Any shortcoming on the part of the prosecution in this regard is fatal to its cause despite the saving clause stated in Section 21 of R.A. No. 9165. 42
The illegal drugs appears to
Apart from the foregoing violations, it is likewise significant to point out that the sachets supposedly recovered from the accused-appellants did not indicate their weight. Even the Inventory/Receipt of Property Seized and the request for laboratory examination is devoid of the actual weight of each of the seized item. And since there was no photograph of the actual inventory, it cannot be ascertained whether the police officers actually weighed the seized items. The failure to indicate the weight of the items, in turn, gives doubt as to whether they were the same items brought to the laboratory for examination.
The recent case of People v. Lopez, 43 expressed that the arresting officers' failure to indicate the quantity of the seized items in the Request for Laboratory Examination precluded the forensic chemist from determining whether the items allegedly seized from accused-appellants had been tampered. The forensic chemist was supposed to verify that the items he received were the very same items seized from accused-appellants using the details in the Request for Laboratory Examination. Without these details, doubts are cast on the integrity of the corpus delicti.
The police officers miserably
A perusal of the records instantly reveal that none of the three (3) required witnesses under Section 21 was present during the buy bust operation and the consequent arrest of accused-appellants. Meanwhile, only an elective official was present during the physical inventory done at the barangay hall. This stark non-compliance with the law is likewise fatal to the prosecution's case for it allows doubt to permeate the mind of the Court, not only as to the existence of the entrapment operations, but, more importantly, on the identity and evidentiary value of the corpus delicti.
The saving clause under the IRR
Concededly, Section 21 of the IRR provides that "non-compliance of these requirements under justifiable grounds, as long as the integrity and the evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures of and custody over said items." However, for this provision to apply, the prosecution must first (1) recognize any lapses on the part of the police officers and (2) be able to justify the same. 44
The CA was thus in error for applying the saving clause in this case in favor of the prosecution. The saving clause indubitably cannot be successfully invoked here in view of the prosecution's failure to acknowledge the blatant lapses of the police officers, compounded by its failure to offer a credible and justifiable ground for their flagrant non-observance of Section 21.
The prosecution failed to establish
In cases involving dangerous drugs, the prosecution has to account for all the links in the chain of custody of the dangerous drug, from the moment of seizure from the accused until it is presented in court as proof of corpus delicti. 45 |The chain of custody rule requires the testimony for every link in the chain, describing how and from whom the seized evidence was received, its condition in which it was delivered to the next link in the chain, and the precautions taken to ensure its integrity.| 46 This is to ensure that the integrity and evidentiary value of the items confiscated from the accused are preserved in drugs operation cases. 47
At present, the Court has been routinely emphasizing the need for the prosecution to account for each link in the chain of custody to ensure the integrity of the seized items, viz.: first, the seizure and marking, if practicable, of the dangerous drug recovered from the accused by the apprehending officer; second, the turnover of the dangerous drug seized by the apprehending officer to the investigating officer; third, the turnover by the investigating officer of the dangerous drug to the forensic chemist for laboratory examination; and fourth, the turnover and submission of the marked dangerous drug seized from the forensic chemist to the court. 48
However, this chain was immediately broken by the prosecution since when, as adverted to earlier, the police officers committed unjustified violations or deviations in the marking, inventory and taking of photographs of the seized evidence. The inconsistent statements of PO1 Cayaga as regards his marking of evidence, alone, already leads to a break in the very first link of the chain, 49 and casts reasonable doubt on the authenticity of the corpus delicti. 50
On another point, the prosecution also failed to establish the second link because the two (2) officers who testified for the prosecution markedly differed as to who took custody of the seized evidence while they were at the police station. PO3 De Jesus testified that they turned over the custody of the items to their investigating officer. However, PO1 Cayaga contradicted PO3 De Jesus's testimony, when he claimed that he took custody of the same during the investigation. 51
Finally, the Court finds that the last two (2) links are likewise missing here because of the insufficiency of the stipulations relative to the testimony of the forensic chemist.
In People v. Pajarin, 52 the Court ruled that in stipulating to dispense with the attendance of the police chemist, the parties should state that he/she: 1) received the seized article marked, properly sealed and intact; 2) resealed it after examination of the content; 3) and placed his own marking on the same to ensure that it could not be tampered pending trial.
All of these required statements were sorely missing in the stipulations of the herein parties. To recall, the parties merely agreed that PCI Dechitan indeed received the specimens for examination, though he did not have knowledge of their origin. And without the appropriate testimony or stipulation of facts regarding the testimony of the forensic chemist, it cannot be determined with moral certainty if the items received for examination were also the same ones presented to the trial court. This break in the chain of custody renders doubtful whether the integrity and evidentiary value of the seized items were duly preserved. 53
Accused-appellants must thus be
It is palpably clear from the Court's rather lengthy discourse that the prosecution's supposedly strong case collapsed as soon as the numerous blunders committed by the police officers were revealed. Lamentably, the lower courts casually turned a blind eye on these defects on a flimsy application of substantial compliance and presumption of regularity of duty.
Necessarily, proof beyond reasonable doubt is imperative to sustain a conviction in criminal cases. 54 Also, the courts must always put in mind that the prosecution bears the burden of proving an accused's guilt through the strength of its own evidence; it cannot merely capitalize on the defense's supposed weaknesses. And unless the prosecution successfully discharges this burden, the accused need not even offer evidence in his or her behalf. He or she would be entitled to an acquittal.
All the foregoing considered, the Court holds that contrary to the finding of the RTC, as affirmed by the CA, the prosecution failed to discharge its burden in this case. Consequently, the accused-appellants must be — as they should have been much earlier — acquitted on reasonable doubt.
WHEREFORE, premises considered, the instant Appeal is GRANTED. The Decision dated 16 March 2018 of the Court of Appeals (CA) in CA-G.R. CR-HC No. 08290 is REVERSED and SET ASIDE. Accused-appellants Sheila Paras y Perido and Marcelino Lontoc y Bayas are ACQUITTED of their respective offenses on reasonable doubt.
Accused-appellant Sheila Paras y Perido is ORDERED IMMEDIATELY RELEASED from detention unless she is being lawfully held for another cause. Let an entry of final judgment be issued immediately.
Accordingly, the Superintendent of the Correctional Institution for Women is DIRECTED to report to this Court the action taken hereon within five (5) days from receipt.
The bail bond filed by accused-appellant Marcelino Lontoc y Bayas for his temporary liberty during his appeal is CANCELLED.
The letter dated April 16, 2021 of Ms. Sheila P. Paras, accused-appellant, stating, in the vernacular, that she is writing to this Court in order to follow-up the status of her case; and the compliance of counsel for accused-appellants with the Resolution dated December 9, 2020, stating that he already complied with the submission of the supplemental brief in PDF file via email, on March 3, 2021, with thereto attached copy of the acknowledgment receipt of the Judicial Records Office as Annexes "A" and "A-1," are both NOTED.
SO ORDERED."
By authority of the Court:
(SGD.) LIBRADA C. BUENADivision Clerk of Court
By:
MARIA TERESA B. SIBULODeputy Division Clerk of Court
Footnotes
* Rayas/Ragas in some parts of the records.
** Shiela in some parts of the records.
1.Rollo, pp. 18-19; see Notice of Appeal dated 26 April 2018.
2.Id. at 3-17; Penned by Associate Justice Zenaida T. Galapate-Laguilles and concurred in by Associate Justices Remedios A. Salazar-Fernando and Jane Aurora C. Lantion of the Second (2nd ) Division of the Court of Appeals, Manila.
3.CA Rollo, pp. 54-59; Records, pp. 98-103; penned by Executive Judge Aurelio G. Icasiano, Jr.
4. Entitled "AN ACT INSTITUTING THE COMPREHENSIVE DANGEROUS DRUGS ACT OF 2002, REPEALING REPUBLIC ACT NO. 6425, OTHERWISE KNOWN AS THE DANGEROUS DRUGS ACT OF 1972, AS AMENDED, PROVIDING FUNDS THEREFOR, AND FOR OTHER PURPOSES," approved on 23 January 2002.
5.Records, p. 1.
6.Id. at 29.
7.Id. at 49; see Order dated 06 August 2012.
8.Rollo, p. 4.
9.Id. at 5.
10.Id.
11.Id. at 5-6.
12.Records, pp. 05-06; see Sinumpaang Salaysay of PO3 De Jesus and PO1 Cayaga, respectively.
13.Id. at 15; see Inventory/Receipt of Property Seized.
14.Rollo, p. 6.
15.Records, p. 20.
16.Supra at note 14.
17.Records, p. 79; see Order dated 03 February 2014.
18.Records, pp. 126; see also Records, pp. 96-98.
19.Supra at note 14.
20.CA rollo, p. 127; Records, pp. 98-99.
21.Id. at 127-128; Id. at 99-100.
22.CA rollo, pp. 58-59.
23.Records, pp. 113-114.
24.Id. at 117.
25.Id. at 118; see Order dated 27 November 2015.
26.Rollo, pp. 16-17.
27. See People v. Marcelino, 639 Phil. 643-655 (2010), G.R. No. 189278, 26 July 2010 [Per J. Velasco].
28.Id.
29.Id.
30.People v. Dayo, G.R. No. 249161 (Notice), 16 September 2020.
31. See People v. Mama, G.R. No. 237204, 01 October 2018 [Per J. Perlas-Bernabe].
32.Id.
33. See People v. Malabanan, G.R. No. 241950, 10 April 2019.
34.Id.
35. RA 9165 was later amended by RA 10640, otherwise known as "AN ACT TO FURTHER STRENGTHEN THE ANTI-DRUG CAMPAIGN OF THE GOVERNMENT, AMENDING FOR THE PURPOSE SECTION 21 OF REPUBLIC ACT NO. 9165, OTHERWISE KNOWN AS THE 'COMPREHENSIVE DANGEROUS DRUGS ACT OF 2002,'" approved on July 15, 2014. In People v. Gutierrez (G.R. No. 236304, November 5, 2018), RA 10640, the Court noted that the amendatory law, which was approved on 15 July 2014, stated that it shall "take effect fifteen (15) days after its complete publication in at least two (2) newspapers of general circulation." A copy of the law was then published on 23 July 2014 in the respective issues of "The Philippine Star" (Vol. XXVIII, No. 359, Philippine Star Metro section, p. 21) and the "Manila Bulletin" (Vol. 499, No. 23; World News section, p. 6). Hence, RA 10640 became effective on 07 August 2014.
36. See People v. Baradi, G.R. No. 238522, 01 October 2018 [Per J. Perlas-Bernabe].
37. See People v. Abueva, G.R. No. 243633, 15 July 2020 [Per J. Reyes, Jr.].
38. TSN, 24 June 2013, p. 9.
39. See People v. Marcelo, G.R. No. 228893, 26 November 2018 [Per J. Gesmundo].
40. See People v. Villarta, G.R. No. 217887, 14 March 2018 [Per J. Castillo].
41. See Gajo v. People, G.R. No. 242979 (Notice), 19 February 2020.
42. See People v. Calates, G.R. No. 214759, 04 April 2018.
43. G.R. No. 248085 (Notice), 15 July 2020.
44. See People v. Ordiz, G.R. No. 206767, 11 September 2019 [Per J. Caguioa].
45. See People v. Sabobo, G.R. No. 241084 (Notice), 12 October 2020.
46. See People v. Zapanta, G.R. No. 230227, 06 November 2019 [Per J. Zalameda].
47. See Santos v. People, G.R. No. 203795 (Notice), 25 January 2021.
48. See Izon v. People, G.R. No. 222509 (Notice), 03 March 2021.
49. See People v. Villarta, G.R. No. 217887, 14 March 2018 [Per J. Castillo].
50. See Gajo v. People, G.R. No. 242979 (Notice), 19 February 2020.
51.Records, p. 12.
52. 654 Phil. 461 (2011), G.R. No. 190640, 12 January 2011 [Per J. Abad].
53. See Santos v. People, G.R. No. 203795 (Notice), 25 January 2021.
54. See De Guzman v. People, G.R. No. 240475, 24 July 2019 [Per J. Leonen].