G.R. No. 179793 - Hidalgo vs. Republic

Allan Gacasan y Langamin was charged with illegal possession and use of false bank notes under Article 168 of the Revised Penal Code.
The underlying information stemmed from a complaint that alleged an incident on November 10, 2018, at the waiting shed in front of Bukidnon Provincial Hospital, where Gacasan was accused of receiving and delivering counterfeit peso bills.
A petition for review on certiorari was filed under Rule 45 of the Rules of Court seeking reversal of the Court of Appeals’ decision that affirmed Gacasan’s conviction.

A confidential agent provided information regarding the proliferation of counterfeit bank notes in Bukidnon and Misamis Oriental.
On October 7, 2018, the CIDG conducted an initial test-buy operation in which an alias “Takyo” sold counterfeit bills to a poseur buyer, later identified as Police Corporal Joseph A. Dalman.
Following this, on November 10, 2018, a second buy-bust operation was orchestrated at the same location where Gacasan was arrested for delivering counterfeit bank notes.

The marked counterfeit bank notes – 100 pieces of counterfeit 1,000-peso bills and 25 pieces of counterfeit 500-peso bills – which were seized during the operation.
Testimony by PCpl. Dalman, who positively identified Gacasan as the individual who delivered the envelope containing the fake notes in exchange for the marked money.
A Certification issued by Atty. Andrew E. Asperin of the Bangko Sentral ng Pilipinas confirming that the seized bank notes were counterfeit.

The chain of custody of the counterfeit bills was emphasized, noting the proper marking and immediately subsequent examination by the bank officer.

Gacasan claimed that he was resting with his sons when an unknown motorcyclist approached and purportedly offered to trade counterfeit money.
He alleged that an unidentified person threw an envelope containing the purported fake money near him, and only subsequently was he apprehended by PCpl. Dalman.
Gacasan maintained that there were serious breaks in the chain of custody of the seized items and questioned whether the bank notes delivered to him were the very same examined by the BSP.
He further contended that he was merely following instructions to deliver an envelope to a poseur buyer, asserting that he did not have actual knowledge of the contents.

The Regional Trial Court (RTC) of Manolo Fortich, Branch 11, found Gacasan guilty beyond reasonable doubt of violating Article 168, basing its decision on:

The establishment of the counterfeit nature of the bank notes by the BSP certification and eyewitness testimony.
The demonstration of Gacasan’s knowledge and his act of receiving payment in exchange for the envelope.

The RTC sentenced Gacasan to an indeterminate penalty ranging from six years (in its maximum period) to ten years, eight months, and one day of imprisonment, plus a fine of PHP 7,500.00.
On appeal, the Court of Appeals (CA) denied Gacasan’s appeal, affirming the RTC’s decision and ordering the cancellation of his bail and issuance of a warrant of arrest.
A subsequent Motion for Reconsideration by Gacasan was also denied, leading to the present Petition for Review on Certiorari.

Whether the Court of Appeals erred in affirming the conviction of Allan Gacasan y Langamin for violation of Article 168 of the Revised Penal Code.
Whether the evidence presented, particularly the testimonies and certification regarding the counterfeit bank notes, was sufficient to establish beyond reasonable doubt that Gacasan knowingly possessed and used the counterfeit currency.
Whether Gacasan’s defense alleging breaks in the chain of custody and a frame-up by law enforcement officers was supported by admissible evidence.