G.R. No. L-63630; April 6, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MEDEL TANGLIBEN Y BERNARDINO, defendant-appellant.

FACTS

The prosecution’s evidence established that on March 2, 1982, police officers on surveillance at a bus terminal in San Fernando, Pampanga, confronted appellant Medel Tangliben, who was acting suspiciously. Upon inspection of his bag, the officers found approximately one kilo of dried marijuana leaves. The appellant allegedly stated he was waiting for a ride to Olongapo City to deliver the marijuana. A field test and subsequent forensic examination confirmed the substance was marijuana. Based on this, the Regional Trial Court convicted him of violating Section 4, Article II of R.A. 6425 (transport of prohibited drugs) and sentenced him to life imprisonment.
The appellant presented a different account. He testified that on March 3, 1982, he was in Subic on business, missed his bus to Manila, and alighted in San Fernando. While waiting for another bus, he was apprehended by police who allegedly took his money. He denied owning the marijuana bag and claimed the evidence was planted. He argued he was never properly informed of his constitutional rights during custodial investigation, rendering any alleged extrajudicial confession inadmissible.

ISSUE

Whether the prosecution proved beyond reasonable doubt the appellant’s guilt for the illegal transport of marijuana.

RULING

The Supreme Court modified the conviction. The legal logic centered on the insufficiency of evidence to prove the specific element of transport. The Court found the appellant’s alleged extrajudicial confession—that he intended to transport the marijuana to Olongapo—inadmissible. The prosecution failed to prove he was informed of his rights to remain silent and to counsel during custodial investigation, as required by the Miranda doctrine adopted in Philippine jurisprudence. Without this confession, the evidence for transport became circumstantial and insufficient.
The Court reasoned that mere possession at a bus terminal, without more, does not conclusively prove intent to transport. The fact that the appellant was arrested in a municipality not his residence and that the marijuana weighed 600 grams (not one kilo as initially stated) did not constitute clear proof of transport beyond reasonable doubt. However, the Court upheld the finding of possession, as the marijuana was unquestionably found in his bag. Consequently, the appellant was properly guilty only of illegal possession of marijuana under Section 8, not illegal transport under Section 4, of R.A. 6425. The penalty was thus reduced to an indeterminate sentence of six years and one day to twelve years imprisonment and a P6,000 fine.