8/25/24, 9:44 PM Case Digest: G.R. No. 93028 - People vs.
Simon y Sunga
Title
People vs. Simon y Sunga
Case Decision Date
G.R. No. 93028 Jul 29, 1994
In the case of People v. Simon y Sunga, the court finds the respondent guilty of
the illegal sale of prohibited drugs based on the positive and corroborated
testimony of the arresting officer, dismissing the alleged inconsistencies and
improbabilities in the testimonies of the prosecution witnesses.
Case Digest (G.R. No. 93028)
Comprehensive
Facts:
In People vs. Martin Simon y Sunga (G.R. No. 93028), decided on July 29, 1994,
Martin Simon y Sunga was charged with violating Section 4, Article II of Republic
Act No. 6425, the Dangerous Drugs Act of 1972.
The indictment alleged that on October 22, 1988, in Barangay Sto. Cristo, Guagua,
Pampanga, Simon sold four tea bags of marijuana to a NARCOM poseur-buyer for
P40.00.
The marijuana was confirmed positive by laboratory examination.
Simon, who had escaped from Camp Olivas, San Fernando, Pampanga, was
rearrested and arraigned on March 2, 1989, where he pleaded not guilty and waived
his right to a pre-trial conference.
During the trial, the prosecution presented evidence showing that a confidential
informant had tipped off the police about Simon's illegal activities.
A buy-bust operation was conducted, leading to Simon's arrest after he sold two tea
bags of marijuana to Sgt. Buenaventura Lopez.
The defense claimed Simon was framed and subjected to physical abuse.
The trial court found him guilty and sentenced him to life imprisonment, a fine of
P20,000, and confiscation of the marijuana.
Simon appealed, arguing errors in the trial court's judgment, including the rejection
of his frame-up defense and the admissibility of evidence.
Issue:
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8/25/24, 9:44 PM Case Digest: G.R. No. 93028 - People vs. Simon y Sunga
Ruling:
1. The Supreme Court affirmed the trial court's decision, rejecting Simon's frame-up
defense.
2. The Court declared Exhibit "G" inadmissible in evidence due to the lack of legal
assistance during custodial investigation.
3. Despite the inadmissibility of Exhibit "G," the C...(Unlock)
Ratio:
1. Frame-up Defense:
The Court found the prosecution's evidence, including the positive and
corroborated testimonies of the arresting officers, more credible than Simon's
uncorroborated claims of frame-up and maltreatment.
The Court emphasized the presumption of regularity in the performance of
official duties and the lack of ill motive on the part of the arresting officers.
2. Admissibility of Exhibit "G":
The Court ruled that Exhibit "G" was inadmissible because Simon was not
assisted by counsel during the custodial investigation, violating his
constitutional rights under the 1987 Philippine Constitution.
The waiver of his right to counsel was not made in writing and in the presence
of counsel, rendering any incriminatory admissions inadmissible.
3. Conviction Justification:
The Court held that the prosecution had proven beyond reasonable doubt that
Simon sold two tea bags of marijuan...
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