People v. Manansala
REITERATIONFacts
The Antecedents: On October 18, 1994, the Philippine National Police (PNP) in Olongapo City conducted a test-buy operation against Chad Manansala y Lagman, a suspected marijuana dealer. Following this, the PNP obtained a search warrant to search Manansala's residence. On October 19, 1994, a search of Manansala's house yielded approximately 750 grams of dried marijuana leaves found inside a wooden box within a cabinet. Also seized was ₱655.00 in cash, which included marked bills used in the test buy. Manansala signed a certification of seized articles along with his father and the Barangay Chairman. The seized marijuana was submitted to the PNP Crime Laboratory, which confirmed it to be marijuana. Manansala was arrested and charged with illegal sale, delivery, giving away, and distribution of 750 grams of marijuana under Section 4 of Republic Act No. 6425 (Dangerous Drugs Act of 1972). Manansala pleaded not guilty. The prosecution filed a motion to amend the information to charge illegal possession under Section 8 of the same law, but the RTC did not act on it. The trial proceeded, and Manansala denied the charge, alleging a frame-up by military men. Procedural History: The Regional Trial Court (RTC), Branch 74, Olongapo City, convicted Manansala for illegal possession of marijuana under Section 8 of Republic Act No. 6425, as amended by Republic Act No. 7659. The RTC found that the prosecution failed to prove the illegal sale but established beyond reasonable doubt that Manansala was in possession of the marijuana. The RTC sentenced him to reclusion perpetua maximum (30 years and 1 day to 40 years) and a fine of ₱750,000.00, with subsidiary imprisonment. The Court of Appeals (CA) affirmed the conviction with modification, sentencing him to reclusion perpetua and a fine of ₱750,000.00. The Petition: Manansala appealed to the Supreme Court, reiterating the errors assigned before the CA, primarily questioning his conviction for illegal possession when the information charged illegal sale, and arguing that illegal possession is not necessarily included in illegal sale.
Issue(s)
Whether the conviction of the accused for illegal possession of prohibited drugs under Section 8 of Republic Act No. 6425, when the information charged illegal sale under Section 4 of the same Act, violated his constitutional right to be informed of the nature and cause of the accusation against him. Whether, under the facts of this case, the offense of illegal possession of marijuana is necessarily included in the offense of illegal sale of marijuana, justifying a conviction for possession when the charge was sale.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. It held that the conviction for illegal possession of marijuana was proper, as the offense of illegal sale necessarily includes the offense of illegal possession. The constitutional right of the accused to be informed of the nature and cause of the accusation was not violated because the information charging illegal sale sufficiently notified him of the possession of the marijuana.
Ratio Decidendi
On the issue of conviction for illegal possession despite the charge of illegal sale: The Court reiterated the principle that when an information charges illegal sale of dangerous drugs, and the evidence fails to establish the sale but proves possession, the accused may be convicted of illegal possession if it is necessarily included in the offense charged. The information alleged that Manansala "did then and there willfully, unlawfully and knowingly engage in selling, delivering, giving away to another and distributing more or less 750 grams or 3/4 kilo of marijuana dried leaves... found in his possession and control." This sufficiently informed Manansala that he was also being held accountable for possessing the said quantity of marijuana. The Court emphasized that the constitutional right to be informed of the nature and cause of the accusation was not transgressed because the information alleged facts that constituted an offense which included the offense established by the evidence. The Court cited the case of People v. Lacerna where it was held that the illegal sale of marijuana absorbs the illegal possession thereof, except in specific circumstances not present here. The Court found that the 750 grams of marijuana seized were the same prohibited drugs subject of the original information, thus supporting the conviction for illegal possession. The Court clarified that while the RTC did not act on the motion to amend the information, the conviction for illegal possession was still valid under the existing information because possession is a necessary ingredient of sale. The Court also noted that the prosecution's motion to amend the information indicated that the 750 grams seized were distinct from the quantity involved in the test buy, further supporting the possession charge. The Court concluded that the CA correctly declared that illegal possession is a crime necessarily included in drug pushing or dealing, and that the conviction was proper under Section 5, Rule 120 of the Rules of Court, which allows conviction for an offense proved that is necessarily included in the offense charged. The Court found no reversible error in the CA's affirmation of the RTC's decision. On the issue of whether illegal possession is necessarily included in illegal sale under the facts of this case: The Court found that the 750 grams of marijuana seized were the same prohibited drugs subject of the original information, thus supporting the conviction for illegal possession. The Court clarified that while the RTC did not act on the motion to amend the information, the conviction for illegal possession was still valid under the existing information because possession is a necessary ingredient of sale. The Court also noted that the prosecution's motion to amend the information indicated that the 750 grams seized were distinct from the quantity involved in the test buy, further supporting the possession charge. The Court concluded that the CA correctly declared that illegal possession is a crime necessarily included in drug pushing or dealing, and that the conviction was proper under Section 5, Rule 120 of the Rules of Court, which allows conviction for an offense proved that is necessarily included in the offense charged.
Main Doctrine
A conviction for illegal possession of prohibited drugs under Section 8 of Republic Act No. 6425 is proper even if the information charged illegal sale under Section 4, provided that the offense of illegal sale necessarily includes the offense of illegal possession, and the evidence proves the latter.