Case Digest (G.R. No. 238589)
Facts:
People of the Philippines v. Allen Bahoyo y Dela Torre, G.R. No. 238589, June 26, 2019, the Supreme Court Third Division, Reyes, A., Jr., J., writing for the Court.In two Informations dated July 17, 2016, Allen Bahoyo y Dela Torre (accused-appellant) was charged with (a) illegal sale of a dangerous drug in violation of Section 5, Article II, Republic Act No. 9165 (Criminal Case No. R‑MKT‑16‑01156) for allegedly selling one heat‑sealed sachet of methamphetamine hydrochloride (0.4835 g) for ₱500; and (b) illegal possession of dangerous drugs in violation of Section 11, Article II, R.A. No. 9165 (Criminal Case No. R‑MKT‑16‑01157) for allegedly having three sachets totaling 0.5818 g of methamphetamine hydrochloride. Bahoyo pleaded not guilty in separate arraignments.
The prosecution presented two police witnesses: PO2 Sherwin Limbauan as the poseur‑buyer and PO2 Leonard Sebial as immediate back‑up, together with police investigators and a forensic chemist who tested the seized sachets. According to the prosecution, a confidential informant led PO2 Limbauan to Bahoyo on July 17, 2016; a marked ₱500 bill was used in the buy‑bust, the transaction was signaled by removal of a ballcap, and additional sachets were recovered after arrest. The team conducted a physical inventory and took photographs at the Makati Police Station in the presence of Bahoyo and a media representative, Cesar Morales, who signed the inventory as the lone independent witness. Laboratory testing confirmed the presence of methamphetamine hydrochloride.
Bahoyo testified in his own defense, denying the charges and claiming he was forcibly brought to the SAID‑SOTG after witnessing a separate commotion; he denied selling or possessing the seized items.
The Regional Trial Court (Makati City, Branch 65) rendered a Decision dated October 26, 2016 finding Bahoyo guilty of both offenses and imposing (1) life imprisonment and ₱500,000 fine for the sale; and (2) 12 years and one day to 14 years and eight months imprisonment and ₱300,000 fine for possession, with credit for time served. The RTC ordered disposition of the seized drugs to the PDEA.
On appeal the Court of Appeals (CA) in CA‑G.R. CR‑HC No. 08744, by Decision dated November 21, 2017 ( penned by Associate Justice Danton Q. Bueser, with Associate Justices Normandie B. Pizarro and ...(Pro-only)
Issues:
- Did the prosecution establish an unbroken chain of custody and preserve the integrity and evidentiary value of the seized drugs under Section 21, Article II of R.A. No. 9165 (as amended by R.A. No. 10640) so that the saved clause could be invoked despite non‑compliance with the required witnesses during inventory?
- In light of any chain‑of‑custody lapse, did the prosecution nevertheless prove beyond reasonable doubt the elements of illegal sale (Sec. 5) and ill...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)