Complaint: Supreme Court First Division People of The Philippines

REPUBLIC OF THE PHILIPPINES
SUPREME COURT
FIRST DIVISION
PEOPLE OF THE
PHILIPPINES,
Plaintiff-
Appellee,
-versus-
PAROK LAMUDAG y RACMAN

@AKMAD
Accused-
Appellant
x--------------------------------------------------
---x
COMPLAINT
Plaintiff, through counsel, respectfully files this criminal case

against accussed and states that:
BACKGROUND FACTS
1. On 6 September 2008, a confidential informant reported to Col. Roderick Mariano, Chief
of the District Anti-Illegal Drug (DAID) Office at U.N. Avenue Police Station in Manila the
alleged drug peddling activities of a certain alias Akmad along Arlegui St., Quiapo, Manila.
Col. Mariano formed a team to conduct a buy bust operation headed by SP04 Rafael
Melencio, P02 Richard Donato as the poseur buyer, and P03 Eliseo Tolentino.
2. P02 Donato prepared the P200.00 marked bill as buy bust money and coordinated with the
Philippine Drug Enforcement Agency (PDEA). At around 6:00 p.m. of the same day, P02
Donato and P03 Tolentino proceeded to Arlegui St., Quiapo, Manila on board the tricycle
of the former, together with the confidential informant. The other police officers boarded a
Tamaraw FX vehicle.
3. When they arrived near the target area, P02 Donato and the confidential informant walked
toward MLQU (Manuel L. Quezon University) where accused-appellant was waiting. The
informant approached accused appellant and introduced P02 Donato as a buyer of shabu.
The latter handed the P200.00 marked money to accused-appellant.
4. After receiving the money, accused-appellant took out from his pocket one (1) heat sealed
plastic sachet and handed the same to P02 Donato. The latter immediately executed the
pre-arranged signal prompting the other police officers to approach and effect the arrest
of accused-appellant.
5. That on or about September 6, 2008, in the city of Manila, Philippines, the said accused,
not being lawfully authorized by law to sell, trade, deliver or give away to another any
dangerous drug, did then and there willfully, unlawfully and knowingly sell ZERO POINT
ZERO SIXTEEN (0.016) gram of white crystalline substance containing methamphetamine
hydrochloride commonly known as SHABU, a dangerous drug contrary to law.
PRAYER
WHEREFORE, premises considered, by reason of the above-

mentioned crime committed by accused, it is most respectfully
prayed of the Honorable Court to order the following:
1. The Court a quo gravely erred in giving weight and credence to the materially inconsistent
and incredible testimonies of the prosecution witnesses.
2. The Court a quo gravely erred in convicting the accused-appellant despite the prosecution's
failure to prove the elements of the crime charged.
3. The court a quo gravely erred in finding the accused-appellant guilty despite the arresting
officers' non-compliance with Section 21 of the Republic Act no. 9165 and its implementing
regulations.
Parok Lamudag
Plaintiff
VERIFICATION and CERTIFICATION OF

NON-FORUM SHOPPING
Republic of the Philippines

Mandaue City
I, Parok Lamudag, Filipino, of legal age from Manila,

Philippines, under oath state that:
1.I am the plaintiff the above-entitled case;

2.I have caused the filing of the foregoing COMPLAINT, and I
verify that its contents are true and correct of my own personal
knowledge and based on authentic records;
3.I hereby certify that we have not commenced any similar action
or filed any claim involving the same respondents in relation to
the same in any court, tribunal or quasi-judicial agency, and to
the best of my knowledge, no such other action or claim is
pending; and
4.I hereby undertake that should I hereafter learn of any other

such action or proceeding, whether pending or terminated, with
any court, tribunal or agency, I shall notify this Honorable Court
of its status within five (5) days from notice.
SUBSCRIBED AND SWORN to before me in Quezon City this

________________, affiant exhibiting to me his ID Card, which ID is
competent evidence of their identity, and on which their pictures and
signatures both appear.
Page No. _______

Doc. No. _______
Book No. _______
Series of 2017.

Complaint: Supreme Court First Division People of The Philippines

Uploaded by

Copyright:

Available Formats

Complaint: Supreme Court First Division People of The Philippines

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Complaint: Supreme Court First Division People of The Philippines

Uploaded by

Copyright:

Available Formats

REPUBLIC OF THE PHILIPPINES

PAROK LAMUDAG y RACMAN

Plaintiff, through counsel, respectfully files this criminal case

WHEREFORE, premises considered, by reason of the above-

VERIFICATION and CERTIFICATION OF

Republic of the Philippines

I, Parok Lamudag, Filipino, of legal age from Manila,

1.I am the plaintiff the above-entitled case;

4.I hereby undertake that should I hereafter learn of any other

SUBSCRIBED AND SWORN to before me in Quezon City this

Page No. _______

You might also like