Case Digest (G.R. No. 243615)
Facts:
Edwin Gementiza Matabilas, G.R. No. 243615, November 11, 2019, the Supreme Court Second Division, Perlas-Bernabe, J., writing for the Court. The respondent is the People of the Philippines.The case arose from an Information filed September 7, 2012 charging petitioner with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165. The prosecution alleged that at about 5:00 p.m. on September 6, 2012 police officers, acting on a tip from a confidential informant, conducted a buy-bust at Villanueva Subdivision, Kidapawan City, and recovered one plastic sachet (0.05 gram) from petitioner. The officers marked, inventoried, and photographed the item in petitioner’s presence and in the presence of Barangay Kagawad Ruel C. Anima and radio reporter Romnick Cabaron; testing at the PNP Provincial Crime Laboratory reported the substance positive for methamphetamine hydrochloride (shabu).
Petitioner denied the charge, claiming he was seeking coconut customers and that officers searched him and his motorcycle, then planted a P500 bill and the sachet, staging the recovery at a store. The Regional Trial Court (RTC), Branch 17, Kidapawan City, found petitioner guilty in a Judgment dated November 12, 2014, sentencing him to life imprisonment and a fine of P500,000, concluding the prosecution proved all elements and that the chain of custody was properly observed. The RTC denied petitioner’s motion for reconsideration on September 2, 2015.
Petitioner appealed to the Court of Appeals (CA) (CA-G.R. CR-HC No. 01488-MIN). In a Decision dated March 22, 2018 the CA affirmed the RTC, treating alleged testimonial inconsistencies as trivial and finding substantial compliance with the chain of custody because the prosecution accounted for the seized drugs from seizure until presentation in court. Petitioner’s motion for reconsideration before the CA was denied in a Resolution dated October 17, 2018. Petitioner then filed a petition f...(Subscriber-Only)
Issues:
- Did petitioner’s procedural lapse in filing a petition under Rule 45 rather than a notice of appeal bar relief?
- Are the alleged inconsistencies in the prosecution witnesses’ testimonies and the defense witnesses’ testimonies sufficient to overturn the RTC’s credibility findings and conviction?
- Did the prosecution’s failure to secure a Department of Justice (DOJ) representative during the inventory and photography — a required witness under the chain of custody rule ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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