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USA College of Law

Abolucion 1-F

Case
People vs Medenilla
Name
Topic General Concept of Due Process
Case No. |
G.R. Nos. 131638-39 | March 26, 2001
Date
Ponente Kapunan, J.
Judges have as much interest as counsel in the orderly and
expeditious presentation of evidence, and have the duty to ask
Doctrine questions that would elicit the facts on the issues involved, clarify
ambiguous remarks by witnesses, and address the points overlooked
by counsel. –Nachura, J.

RELEVANT FACTS
 Accused-appellant Loreto Medenilla y Doria was criminally charged for
violating Section 151 and 162, Article 3 of R.A No. 6425, as amended,
otherwise known as the Dangerous Drugs Act of 1972.
 On or about April 16, 1996, Medenilla did then and there and there willfully,
unlawfully and feloniously sell, deliver and give away to 5.08 grams and had
in his possession and/or under his custody four (4) transparent plastic bags
containing white crystalline substance with a total weight of 200.45 grams,
which were found positive to the test for methampetamine hydrochloride
(shabu).
 Accused-appellant pleaded not guilty to both charges against him.
 The prosecution presented the testimonies of the two police officers who
conducted the buy-bust operation. Meanwhile, Medenilla presented different
version of the events leading to his arrest.
 The trial court found the accused-appellant guilty as charged. Hence, the
appeal.

ISSUE: Whether or not the accused was accorded his right to due process
(procedural).

RULING:

YES.
The accused cited in his appeal brief a single instance when the judge
allegedly revealed his bias.

 The Court, however, failed to see how this single noted instance of
questioning can justify a claim that the trial judge was biased. They have
exhaustively examined the transcript of stenographic notes and determined
that the trial judge was more than equitable in presiding over the hearings
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USA College of Law
Abolucion 1-F

of this case. Moreover, a judge is not prohibited from propounding


clarificatory questions on a witness if the purpose of which is to arrive at a
proper and just determination of the case.
 Trial judges in this jurisdiction are judges of both the law and the facts, and
they would be negligent in the performance of their duties if they permitted
a miscarriage of justice as a result of a failure to propound a proper
question to a witness which might develop some material bearing upon the
outcome.
 In the exercise of sound discretion, he may put such question to the witness
as will enable him to formulate a sound opinion as to the ability or the
willingness of the witness to tell the truth.
 A judge may examine or cross-examine a witness. He may propound
clarificatory questions to test the credibility of the witness and to extract
the truth. He may seek to draw out relevant and material testimony though
that testimony may tend to support or rebut the position taken by one or the
other party. It cannot be taken against him if the clarificatory questions he
propounds happen to reveal certain truths which tend to destroy the theory
of one party. 

RULING
WHEREFORE , the decision of the Regional Trial Court of Pasig is hereby
AFFIRMED WITH MODIFICATIONS. Accused-appellant Loreto Medenilla y Doria
is hereby found GUILTY of violating Sections 15 and 16 of Republic Act No. 6425, as
amended by Republic Act No. 7659, and hereby sentenced: (a) in Criminal Case No.
3618-D, to suffer an indeterminate sentence of 6 months of arresto mayor to 4 years
and 2 months of prision correccional; and (b) in Criminal Case No. 3619-D, to suffer
the penalty of reclusion perpetua and to pay a fine of Two Million Pesos
(P2,000,000.00).

NOTES

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1
SEC. 15. Sale, Administration, Dispensation, Delivery, Transportation and Distribution of Regulated Drugs. The penalty of
reclusion perpetua to death and a fine ranging from five hundred thousand pesos to ten million pesos shall be imposed
upon any person who, unless authorized by law, shall sell, dispense, deliver, transport, or distribute any regulated drug.
Notwithstanding the provisions of Section 20 of this Act to the contrary, if the victim of the offense is a minor, or should a
regulated drug involved in any offense under this Section should be the proximate cause of the death of a victim thereof,
the maximum penalty herein provided shall be imposed.

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SEC. 16. Possession or Use of Regulated Drugs. the penalty of reclusion perpetua to death and a fine ranging from five
hundred thousand pesos to ten million pesos shall be imposed upon any person who shall possess or use any regulated
drug without the corresponding license or prescription, subject to the provisions of Section 20 hereof.

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