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PEOPLE v. JERRY SANTOS Y MACOL

This case has been cited 8 times or more.

2013-06-05
PEREZ, J.
To begin with, it is a fundamental principle that findings of the trial courts which are factual in nature and which involve the credibility of witnesses are accorded respect when no glaring errors; gross misapprehension of facts; and speculative, arbitrary and unsupported conclusions can be gathered from such findings.[25] This is so because the trial court is in a unique position to observe the witnesses' demeanor on the witness stand.[26] The above rule finds an even more stringent application where said findings are sustained by the Court of Appeals,[27] like in the case under consideration.
2012-02-29
LEONARDO-DE CASTRO, J.
In People v. Santos,[47] the Court ruled as follows: Fundamental is the principle that findings of the trial courts which are factual in nature and which involve the credibility of witnesses are accorded respect when no glaring errors; gross misapprehension of facts; and speculative, arbitrary and unsupported conclusions can be gathered from such findings.  The reason for this is that the trial court is in a better position to decide the credibility of witnesses, having heard their testimonies and observed their deportment and manner of testifying during the trial.  The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[48]
2011-08-31
PERALTA, J.
In the present case, at the time of petitioner's arraignment, there was no objection raised as to the irregularity of his arrest. Thereafter, he actively participated in the proceedings before the trial court. In effect, he is deemed to have waived any perceived defect in his arrest and effectively submitted himself to the jurisdiction of the court trying his case. At any rate, the illegal arrest of an accused is not sufficient cause for setting aside a valid judgment rendered upon a sufficient complaint after a trial free from error. It will not even negate the validity of the conviction of the accused.[13]
2011-08-15
PERALTA, J.
In the case at bar, petitioner never objected to the irregularity of his arrest before his arraignment.  Moreover, he actively participated in the proceedings before the RTC. Thus, he is deemed to have waived any perceived defect in his arrest and effectively submitted himself to the jurisdiction of the court trying his case. At any rate, the illegal arrest of an accused is not sufficient cause for setting aside a valid judgment rendered upon a sufficient complaint after a trial free from error. It will not even negate the validity of the conviction of the accused.[11]
2010-09-15
DEL CASTILLO, J.
For alibi to prevail, the established doctrine is that the accused must prove not only that he was at some other place at the time of the commission of the crime but also that it was physically impossible for him to be at the locus criminis or within its immediate vicinity.[25]  Physical impossibility means that the accused was at such other place for such a length of time that it was impossible for him to have been at the crime scene either before or after the time he was at such other place.[26]
2010-07-05
DEL CASTILLO, J.
Petitioner's claim that his warrantless arrest is illegal lacks merit.  We note that nowhere in the records did we find any objection interposed by petitioner to the irregularity of his arrest prior to his arraignment.  It has been consistently ruled that an accused is estopped from assailing any irregularity of his arrest if he fails to raise this issue or to move for the quashal of the information against him on this ground before arraignment.  Any objection involving a warrant of arrest or the procedure by which the court acquired jurisdiction over the person of the accused must be made before he enters his plea; otherwise, the objection is deemed waived.[5]  In this case, petitioner was duly arraigned, entered a negative plea and actively participated during the trial.  Thus, he is deemed to have waived any perceived defect in his arrest and effectively submitted himself to the jurisdiction of the court trying his case.  At any rate, the illegal arrest of an accused is not sufficient cause for setting aside a valid judgment rendered upon a sufficient complaint after a trial free from error.  It will not even negate the validity of the conviction of the accused.[6]
2010-05-06
LEONARDO-DE CASTRO, J.
Thus, in People v. Santos,[19] which has similar factual antecedents as this case, the Court had the occasion to rule that: There is conspiracy when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. The same degree of proof necessary to prove the crime is required to support a finding of criminal conspiracy. Direct proof, however, is not essential to show conspiracy. It need not be shown that the parties actually came together and agreed in express terms to enter into and pursue a common design. Proof of concerted action before, during and after the crime, which demonstrates their unity of design and objective is sufficient. As correctly held by the trial court, the act of appellant Santos in receiving the marked money from PO3 Luna and handing the same to appellant Catoc, who in turn gave a sachet containing shabu to appellant Santos to give the policeman, unmistakably revealed a common purpose and a community of interest indicative of a conspiracy between the appellants. (Emphasis ours.)
2009-09-17
VELASCO JR., J.
In the prosecution for illegal sale of dangerous drugs, what is material is proof that the transaction or sale actually took place, coupled with the presentation in court of the traded substance--the object evidence which is the core of the corpus delicti.[16] These requirements have been sufficiently established in the instant case. What is more, the integrity of the evidence is presumed to be preserved unless there is a showing of bad faith, ill will, or proof that the evidence has been tampered with. Capco has the burden to show that the evidence was tampered or meddled with to overcome a presumption of regularity in the handling of exhibits by public officers.[17] Capco failed in this respect.