Yap v. People
REITERATIONFacts
1. The Antecedents: Petitioner Yap Peng Chong was charged, along with several co-accused, with violating Republic Act No. 3720, the Food, Drug and Cosmetic Act. The charge stemmed from the alleged conspiracy to manufacture, sell, distribute, and deliver fake or adulterated and mislabelled drugs without proper authority. Two of the co-accused remained at large, and the trial proceeded against Yap Peng Chong, Rolando Lacdao, and Mario Uy. 2. Procedural History: The Court of First Instance of Rizal convicted petitioner Yap Peng Chong and Rolando Lacdao, sentencing them to an indeterminate penalty of six (6) months and one (1) day to five (5) years, a fine of P1,000.00 each, and subsidiary imprisonment. Mario Uy was acquitted. Yap Peng Chong appealed this decision to the Court of Appeals, which affirmed the conviction, modifying only the specific designation of the penalty. The Court of Appeals' decision and subsequent resolution denying a motion for reconsideration are the subject of the current petition. 3. The Petition: This petition for review challenges the Court of Appeals' decision. Petitioner argues that his extrajudicial confession, which he claims was involuntary due to maltreatment and threats, was improperly admitted as evidence. He further contends that the evidence presented was insufficient to overcome the presumption of innocence and warrant his conviction. The petition seeks to overturn the findings of the lower courts and secure an acquittal.
Issue(s)
Whether the petitioner's extrajudicial confession was involuntary and thus inadmissible as evidence. Whether the evidence presented, including but not limited to the seized drugs and the NBI agent's testimony, was sufficient to warrant the conviction of the petitioner beyond reasonable doubt.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. The conviction of the petitioner for violation of Republic Act No. 3720 stands.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Supreme Court found no merit in the petitioner's claim that his extrajudicial confession was involuntary. The Court noted that the confession was dated February 1, 1967, the same day of the raid and arrest, questioning why brutal treatment would occur on the first day. Furthermore, the petitioner failed to present any evidence of maltreatment during the trial, nor did he complain to the swearing officer. The appellate court's finding that the confession was voluntary was given credence, as there were no suspicious circumstances casting doubt on its integrity. The Court emphasized that the petitioner's allegations of maltreatment were unsubstantiated by any proof. On the sufficiency of evidence: Even without considering the extrajudicial confession, the Supreme Court held that there was sufficient evidence to establish the guilt of the petitioner beyond reasonable doubt. The prosecution presented evidence showing that NBI agents conducted a raid based on information about the manufacture of fake drugs. The petitioner was apprehended at the premises, and he acknowledged the inventory of seized items. An NBI agent had previously purchased drugs from the petitioner, which were later found to be fake through laboratory analysis. The analysis confirmed that the seized drugs were adulterated and their ingredients did not conform to specifications under Republic Act No. 3720, although they were not injurious to health. This corroborating evidence, independent of the confession, was deemed sufficient for conviction.
Main Doctrine
An extrajudicial confession, even if allegedly obtained through maltreatment, is admissible as evidence if the allegations of coercion are unsubstantiated and the confession is corroborated by other evidence establishing guilt beyond reasonable doubt. The appellate court's findings of fact, particularly regarding the voluntariness of a confession, are generally binding on the Supreme Court.