Case Digest (G.R. No. 229787)
Facts:
The case involves Ricky Anyayahan y Taronas (petitioner) against the People of the Philippines (respondent), with the decision rendered on June 20, 2018, by the Second Division of the Supreme Court. The events leading to the case began on January 9, 2013, in Marikina City, where Anyayahan was charged with two counts: Illegal Sale and Illegal Possession of Dangerous Drugs, specifically Methamphetamine Hydrochloride (shabu), under Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002. The prosecution's narrative indicated that at approximately 6:00 PM, a buy-bust operation was initiated after receiving a tip-off about Anyayahan selling drugs from his residence. A buy-bust team, led by Senior Police Officer (SPO) 1 Arnel Manuel, included SPO1 Badalf V. Monte as the poseur-buyer. During the operation, SPO1 Monte approached Anyayahan, posing as a buyer, and handed him marked money in exchange for a sachet of shabu. After the transaction, Anyayahan was a...
Case Digest (G.R. No. 229787)
Facts:
Background of the Case
The case involves petitioner Ricky Anyayahan y Taronas (Anyayahan), who was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II of Republic Act No. (RA) 9165, also known as the "Comprehensive Dangerous Drugs Act of 2002." The charges stemmed from a buy-bust operation conducted on January 9, 2013, in Marikina City.
Buy-Bust Operation
- Report and Formation of Team: The Station Anti-Illegal Drugs Special Operations Task Group (SAID-SOTG) received a tip from a confidential informant that Anyayahan was selling drugs in his residence. A buy-bust team was formed, with SPO1 Badalf V. Monte (SPO1 Monte) as the poseur-buyer.
- Transaction: SPO1 Monte and the informant approached Anyayahan, who agreed to sell shabu worth P300.00. SPO1 Monte handed over marked money, and Anyayahan handed over a sachet of suspected shabu. Another sachet was found in Anyayahan’s pocket during the arrest.
- Seizure and Inventory: The seized items were marked, photographed, and inventoried at the scene. The inventory was signed by a barangay official and a media representative. The items were later turned over to the crime laboratory, where they tested positive for Methamphetamine Hydrochloride (shabu).
Defense’s Version
Anyayahan denied the charges, claiming he was framed. He alleged that he was accosted by four men who introduced themselves as policemen, frisked him, and planted the drugs and money on him.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Chain of Custody Requirements: Section 21 of RA 9165 mandates that the inventory and photography of seized drugs must be conducted in the presence of the accused or their representative, a media representative, a Department of Justice (DOJ) representative, and an elected public official. This ensures the integrity of the evidence.
- Non-Compliance with Procedure: In this case, the prosecution failed to prove that the required witnesses were present during the inventory and photography. SPO1 Monte admitted that the barangay official and media representative signed the inventory only after it was completed, and there was no DOJ representative present.
- Justifiable Grounds for Non-Compliance: While non-compliance with Section 21 is allowed under justifiable grounds, the prosecution must prove that such grounds exist and that the integrity of the evidence was preserved. Here, no justifiable grounds were provided, and the integrity of the seized items was compromised.
- Presumption of Regularity Overcome: The defense successfully rebutted the presumption of regularity in the performance of official duties by the police officers, as the procedural lapses were unjustified.
- Importance of Procedural Safeguards: The Court emphasized that strict compliance with procedural safeguards is essential to protect the rights of the accused and ensure the integrity of the judicial process.
Conclusion:
The Supreme Court reversed the CA’s decision and acquitted Anyayahan due to the prosecution’s failure to establish an unbroken chain of custody and comply with the mandatory procedures under RA 9165. The Court reiterated the importance of procedural safeguards in protecting the rights of the accused, even in the government’s campaign against illegal drugs.