Case Digest (G.R. No. 237803)
Facts:
- The accused-appellant, Allan Alon-Alon y Lizarda, was charged with the illegal sale of dangerous drugs, specifically Methamphetamine Hydrochloride (shabu), under Section 5, Article II of Republic Act No. 9165.
- The incident occurred on August 13, 2012, in San Pedro, Laguna, Philippines.
- A buy-bust operation was conducted by law enforcement after receiving confidential information about the accused's drug activities.
- A police poseur-buyer purchased a heat-sealed plastic sachet containing shabu for P300.00 from the accused.
- The buy-bust team marked the buy-bust money and the seized sachet.
- The inventory and photography of the seized items were conducted only at the police station, with the accused and a media representative present, but without a DOJ representative or an elected public official.
- A laboratory examination confirmed that the seized item contained shabu.
- The accused denied the allegations, claiming he was merely conversing with a tenant when police entered his home and took him for questioning.
- The Regional Trial Court (RTC) found the accused guilty and sentenced him to life imprisonment and a fine of P500,000.
- The Court of Appeals (CA) affirmed this judgment with modifications regarding parole eligibility, leading the accused to appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the appeal, reversed the Court of Appeals' decision, and acquitted the accused-appellant due to the prosecution...(Unlock)
Ratio:
- The Supreme Court highlighted that appeals in criminal cases allow for a thorough review, enabling correction of errors in lower court judgments.
- To secure a conviction for illegal sale of dangerous drugs, the prosecution must prove the identities of the buyer and seller, the object of sale, and the delivery of the item sold along with payment.
- The integrity of the seized drug, serving as the corpus delicti, must be established with moral certainty, requiring an unbroken chain of custody from seizure to court presentation.
- The Court identified significant lapses in the chain of custody, noting that the inventory and photography were not conducted in the presence of all required witnesses, specifically lacking a DO...continue reading
Case Digest (G.R. No. 237803)
Facts:
The case involves the accused-appellant Allan Alon-Alon y Lizarda, who was charged with the illegal sale of dangerous drugs, specifically Methamphetamine Hydrochloride (shabu), under Section 5, Article II of Republic Act No. 9165. The events transpired on August 13, 2012, in San Pedro, Laguna, Philippines. The prosecution's case stemmed from a buy-bust operation initiated by law enforcement after receiving confidential information about the accused's involvement in illegal drug activities. During the operation, a police poseur-buyer successfully purchased a heat-sealed plastic sachet containing shabu for P300.00 from the accused. Following the transaction, the buy-bust team marked the buy-bust money and the seized sachet. However, the inventory and photography of the seized items were conducted only at the police station, with the presence of the accused and a media representative, but lacking a representative from the Department of Justice (DOJ) and an elected public official. The seized item was later confirmed to contain shabu through a laboratory examination.
In his defense, the accused-appellant denied the allegations, claiming that he was merely conversing with a tenant when police officers entered his home, searched for drugs, and subsequently took him to the police station for questioning. The Regional Trial Court (RTC) of San Pedro City rendered a judgment on February 18, 2015, finding the accused guilty beyond reasonable doubt and sentenc...