Tuesday, June 20, 2017

Case Digest: People vs. Noque

G.R. No. 175319
January 15, 2010
People vs. Joselito Noque y Gomez

Facts:
Appellant Joselito Noque Gomez was subject to a buybust operation, from which articles alleged to be methamphetamine hydrochloride (shabu) were seized. The seized articles were taken to the police station and submitted to the crime laboratory for examination to determine the chemical composition of the crystalline substance, which positively resulted to be ephedrine, a regulated drug.

Lower Courts prounounced appellant guilty beyond reasonable doubt for the violation of Section Sections 15 and 16 of RA 6425 that define and penalize the crimes of illegal sale and illegal possession of regulated drugs.

Joselito appealed contending that the lower courts erred in convicting him despite the information, alleging methamphetamine hydrochloride as the seized item when the drug actually seized was ephedrine. Joselito contends that his constitutional right to be informed of the nature and cause of the accusations against him.

Ruling:
The Court affirmed the lower courts decision that the designations and allegations in the information are for the crimes of illegal sale and illegal possession of regulated drugs. Ephedrine is a regulated drug, pursuant to Board Resolution No. 2, Series of 1988. Under Sections 4 and 5, Rule 120 of the Rules of Court, an offense charged is necessarily included in the offense proved when the essential ingredients of the former constitute or form part of those constituting the latter. Appellant’s right to be informed of the charges against him has not been violated because where an accused is charged with a specific crime, he is duly informed not only of such specific crime but also of lesser crimes or offenses included therein.

The Court also affirmed the CA’s decision regarding the penalty imposed on appellant in relation to the amount of shabu seized (in this case, 0.060 grams and 2.754 grams. It held that in the absence of any mitigating or aggravating circumstances in this case, the penalty should be imposed in its medium period, ranging from six months of arresto mayor, as minimum, to two years, four months and one day of prision correccional, as maximum.)


As to the violation of Section 16, Article III of RA 6425, as amended, penalty of reclusion perpetua and a fine of P500,000.00 was imposed on the appellant for the possession of 339.6075 grams  of prohibited drugs without license or prescription.

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