PEOPLE vs. MORILLA

G.R. No. 189883

February 5, 2014

FACTS:

During a checkpoint, Mayor Mitra, Willie Yang and Ruel Dequilla were caught illegally transporting methamphetamine hydrochloride by means of two (2) motor vehicles, namely a Starex van with commemorative plate to read "Mayor" and a municipal ambulance. 

During the trial, Mayor Mitra argued that he was without any knowledge of the contents of the sacks and explained that he only accommodated the request of a certain Ben Tan because the latter bought his fishing boat. Likewise, Morilla insisted that he thought what he was transporting were wooden tiles and electronic spare parts together with Dequilla. The other passenger of the ambulance, Yang, in his defense, did not bother to inquire about the contents of the vehicle as he was merely an accommodated passenger of the ambulance.

ISSUES: 

1) Whether or not intent or knowledge is material in determining the culpability of an accused in drug cases (NO)

2) Whether or not the finding of conspiracy is correct (YES)

HELD:

1) NO, intent or knowledge is not material in determining the culpability of an accused in drug cases.

The very act of transporting methamphetamine hydrochloride is malum prohibitum since it is punished as an offense under a special law. Morilla and Mayor Mitra were caught in flagrante delicto in the act of transporting the dangerous drugs on board their vehicles. "Transport" as used under the Dangerous Drugs Act means "to carry or convey from one place to another." It was well established during trial that Morilla was driving the ambulance following the lead of Mayor Mitra, who was driving a Starex van going to Manila. The fact of transportation of the sacks containing dangerous drugs need not be accompanied by proof of criminal intent, motive or knowledge.

2) YES, the finding of conspiracy is correct.

The finding of conspiracy by both courts is correct. A conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. To determine conspiracy, there must be a common design to commit a felony.

Morilla’s argument that the mere act of driving the ambulance on the date he was apprehended is not sufficient to prove that he was part of a syndicated group involved in the illegal transportation of dangerous drugs is misplaced. 

In 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. The assent of the minds may be and, from the secrecy of the crime, usually inferred from proof of facts and circumstances which, taken together, indicate that they are parts of some complete whole. In this case, the totality of the factual circumstances leads to a conclusion that Morilla conspired with Mayor Mitra in a common desire to transport the dangerous drugs. Both vehicles loaded with several sacks of dangerous drugs, were on convoy from Quezon to Manila. If indeed he was not involved in conspiracy with Mayor Mitra, he would not have told the police officers that he was with the mayor.

*The above case digest is only a guide. I highly recommend that you read the FULL TEXT.