Case Digest (G.R. No. 231902)
Facts:
On July 28, 2005, in Quezon City, Police Superintendent Acierto of the Philippine National Police Anti-Illegal Drug Special Operation Task Force (PNPAIDSOTF), acting on a tip from a confidential informant about Chinese-led drug trafficking by Peter Angeles and his group, coordinated a buy-bust with the Quezon City Police and PDEA. The informant’s contact “Sexy” negotiated delivery of “shabu” at Hap Chan Restaurant via a silver Toyota Revo, driven that afternoon by Dennis Oliver Castronuevo Luna (petitioner Luna), a hired driver who testified he had no ownership or knowledge of any contraband. During the operation, poseur-buyer SPO3 Parreño (“Mike”) retrieved a blue bag from the back seat, opened it to find six packages of white crystalline substance, and signaled arrest. Luna was told his rights, the substance was submitted to the crime lab and tested positive for methylamphetamine hydrochloride, and the requisites of Section 21, Article II of R.A. No. 9165 were not observed. On...Case Digest (G.R. No. 231902)
Facts:
- Procedural Background
- Petition for Review on Certiorari under Rule 45 filed by petitioner Dennis Oliver Castronuevo Luna (Luna) against the Court of Appeals (CA) Decision (Jan. 5, 2017) and Resolution (May 29, 2017) affirming his conviction.
- Conviction by RTC Branch 79, Quezon City (Sept. 14, 2015) for violation of Section 11, Article II of R.A. No. 9165 (Illegal Possession of Dangerous Drugs).
- Prosecution’s Version
- July 10, 2005: PNPAIDSOTF receives tip on drug trafficking by Peter Angeles’ group; surveillance coordinated with QCPD and PDEA on July 28, 2005.
- At around 4:30 PM in front of Hap Chan Restaurant, “Sexy” instructs poseur-buyer (“Mike”) to get a blue bag from a silver Toyota Revo (plate XHY 278).
- SPO3 Parreño opens Revo door, is handed the bag by Luna; inside are six brown envelopes of white crystalline substance.
- Luna is arrested; items inventoried later at Camp Crame without required witnesses; laboratory confirms “shabu.”
- Defense’s Version
- Luna: lawful driver-for-hire for Susan Lagman, occasionally drives for “Sexy.”
- On July 28, 2005, he drove “Sexy” to various locations, then was instructed to wait at Hap Chan and let “Mike” retrieve her bag.
- He did not own or control the bag or its contents; was unaware it contained drugs.
- Trial Court and CA Decisions
- RTC finds Luna guilty beyond reasonable doubt; sentences him to life imprisonment and ₱1,000,000 fine; forfeits drugs to PDEA.
- CA affirms RTC Decision in toto.
Issues:
- Whether the prosecution proved beyond reasonable doubt that Luna knowingly and intentionally possessed the seized drugs (animus possidendi).
- Whether the integrity and evidentiary value of the seized drugs were preserved in compliance with the chain of custody rule under Section 21, Article II of R.A. No. 9165.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)