People v. Nillos
REITERATIONFacts
The Antecedents: Elmer Nillos y Palsario was charged with violation of Section 4, Article Two of Republic Act No. 6425, as amended by P.D. No. 1675 (Dangerous Drugs Act of 1972). The information alleged that Leon Peña y Cartel delivered 37 match boxes of dried marijuana leaves to Elmer Nillos for sale, and Nillos subsequently gave these to a poseur-buyer from the Constabulary Anti-Narcotics Unit (CANU). Procedural History: The Court of First Instance of Negros Occidental found Elmer Nillos guilty beyond reasonable doubt and sentenced him to twelve (12) years and one (1) day of reclusion temporal as minimum to reclusion perpetua as maximum, a fine of P20,000.00, and costs. Leon Peña was acquitted on grounds of reasonable doubt. Nillos appealed to the Intermediate Appellate Court (IAC). The IAC affirmed the conviction but modified the penalty to life imprisonment, noting that the law prescribed life imprisonment to death. The IAC then transmitted the case to the Supreme Court for review. The Petition: The accused-appellant, Elmer Nillos, appealed the decision of the IAC, primarily assailing his conviction and the penalty imposed.
Issue(s)
Whether the evidence presented sufficiently proved the guilt of the accused-appellant beyond reasonable doubt. Whether the extra-judicial confession of the accused-appellant was admissible and voluntary. Whether the penalty imposed was correct.
Ruling
The Supreme Court affirmed the judgment of conviction imposed upon Elmer Nillos, sentencing him to suffer the penalty of reclusion perpetua and to pay a fine of P20,000.00 and costs. The 37 match boxes of marijuana leaves were ordered confiscated in favor of the government.
Ratio Decidendi
On the sufficiency of evidence: The Court found that even if the extra-judicial confession of the accused-appellant were completely disregarded, there was more than enough evidence to sustain a judgment of conviction. The testimonies of prosecution witnesses, including CANU agents and forensic chemists, proved beyond reasonable doubt the accused-appellant's guilt of the offense charged. The Court found the accused-appellant's uncorroborated story that he was carrying the marijuana for analysis and not for sale to be incredible. The prosecution's evidence established that the accused-appellant was apprehended in the act of selling 37 match boxes containing marijuana leaves to a poseur-buyer. The chain of custody of the confiscated marijuana was also shown to have been maintained, with chemical examination confirming the substance to be marijuana. On the admissibility and voluntariness of the extra-judicial confession: The appellate court found no basis for the contention that the sworn statement was secured through force. The Court noted that the accused-appellant himself admitted that many details contained in his confession were true during his examination in court. Furthermore, he did not complain of any maltreatment when brought before the fiscal to swear to the truth of his statement, nor did he file any complaint thereafter. The presence of details in the confession that only the appellant could have known, and matters that were exculpatory, indicated its voluntariness. On the correctness of the penalty: The Court affirmed the penalty of reclusion perpetua and a fine of P20,000.00, as imposed by the trial court and affirmed by the IAC, which was consistent with Section 4 of Republic Act 6425 as amended by P.D. No. 1675.
Main Doctrine
The Court affirmed the conviction of the accused for violation of Section 4, Article Two of Republic Act No. 6425, as amended, finding sufficient evidence to sustain the judgment of conviction even if the extra-judicial confession were disregarded. The Court also affirmed the penalty of reclusion perpetua and a fine of P20,000.00.