Title
People vs. Buniag y Mercadera
Case
G.R. No. 217661
Decision Date
Jun 26, 2019
Accused acquitted due to prosecution's failure to comply with chain of custody rules under RA 9165, compromising evidence integrity.
A

Case Digest (G.R. No. 70451)

Facts:

People of the Philippines charged Ferdinand Buniag y Mercadera with violating Section 5, Article II of R.A. 9165 for allegedly selling marijuana during a buy-bust on August 9, 2008 in Olape St., Zone 2, Bayabas, Cagayan de Oro City. The RTC convicted him, but found only an attempt to sell and also held him liable for delivery, while ruling that the chain of custody was adequately established.

On appeal, the Court of Appeals affirmed but modified the conviction to violation of Section 26(b), Article II of R.A. 9165, holding that the case involved an aborted sale and that noncompliance with Section 21 was not fatal.

Issues:

  • Whether the CA erred in finding Buniag guilty beyond reasonable doubt for violation of Section 26(b), Article II of R.A. 9165.
  • Whether the prosecution proved the corpus delicti for attempted illegal sale given alleged breaches of Section 21, Article II of R.A. 9165 and defects in the buy-bust handling of the seized drugs.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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