Title
Supreme Court
People vs. Ching
Case
G.R. No. 223556
Decision Date
Oct 9, 2017
Manuel Lim Ching acquitted due to procedural lapses in chain of custody, compromising evidence integrity under RA 9165.

Case Digest (G.R. No. 137823)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves accused-appellant Manuel Lim Ching, who was charged before the Regional Trial Court (RTC) of Catarman, Northern Samar, and later convicted in connection with multiple informations under Republic Act (RA) No. 9165 (the Comprehensive Dangerous Drugs Act of 2002).
    • Four separate criminal cases (Criminal Case Nos. C-3522, C-3523, C-3533, and C-3524) were consolidated, wherein Ching faced charges for:
      • Illegal possession of dangerous drugs (Section 11, Article II of RA 9165).
      • Illegal possession of drug paraphernalia (Section 12, Article II of RA 9165).
      • Illegal sale of dangerous drugs (Section 5, Article II of RA 9165).
      • Maintenance of a drug den (Section 6, Article II of RA 9165), on which he was ultimately acquitted.
  • Facts of the Incident
    • Date, Time, and Place
      • The incident occurred on June 29, 2003, around 4:00 in the afternoon.
      • The location was Purok 4, Barangay Jose Abad Santos, Municipality of Catarman, Province of Northern Samar, Philippines.
    • Nature of the Alleged Offenses
      • In Criminal Case No. C-3522, Ching was accused of possessing various sachets of “shabu” (methamphetamine hydrochloride) without the required licenses or permits.
      • In Criminal Case No. C-3523, he was charged with possessing drug paraphernalia/tools (including aluminum foils, improvised tooters, plastic tooter, alcohol lamp, plastic case, disposable lighters, scissors, and cutter blades) intended for use in the consumption of dangerous drugs.
      • In Criminal Case No. C-3533, he was charged with the illegal sale of shabu, evidenced by a buy-bust operation involving a designated police poseur-buyer, resulting in the sale of sachets with specific weights and monetary values.
      • In Criminal Case No. C-3524, he was charged with maintaining a drug den in his residence where drugs and paraphernalia were stored and used; however, he was later acquitted on this charge.
  • Conduct of the Buy-Bust Operation and Subsequent Seizure
    • Surveillance and Operation
      • The police conducted surveillance and a test-buy operation using a civilian asset to purchase a sachet of suspected shabu.
      • Police Superintendent Isaias B. Tonog led the operation, assembling a team which included PO1 Mauro Ubaldo Lim, the designated poseur-buyer.
    • The Operation
      • Upon arrival at Ching’s residence, PO1 Lim bought a sachet of shabu (valued at P500.00) from Ching.
      • After receiving the item and giving the pre-arranged signal, the rest of the team moved in, leading to Ching’s flight into his room and eventual arrest.
    • Subsequent Evidence Recovery
      • A search of the premises revealed:
        • Three locations where sachets of shabu were found: in a chicken cage outside, on wooden frames inside, and in a pail outside the house.
ii. An adjacent makeshift structure, which contained multiple pieces of drug paraphernalia.
  • The seized sachets were marked (MLC-1 to MLC-9) and later submitted to the Philippine Drug Enforcement Agency (PDEA) and then to the PNP Regional Crime Laboratory for examination.
  • Laboratory Testing and Identification
    • Forensic tests confirmed that eight of the nine sachets tested positive for methamphetamine hydrochloride (shabu); one sachet (MLC-7) tested negative.
  • Ching’s Denial and Defense
    • During arraignment, Ching pleaded not guilty and denied involvement, attributing his arrest to a personal vendetta with P/Supt. Tonog.
    • He claimed that the police's actions during the raid involved irregularities, including the handling of evidence, which led to his detention.
  • Trial Court and Appellate Proceedings
    • RTC Decision (June 17, 2013)
      • Conviction in Criminal Case No. C-3522 for illegal possession of shabu, with a penalty ranging from 12 years and 1 day to 20 years of imprisonment plus a fine of P100,000.00.
      • Conviction in Criminal Case No. C-3523 for illegal possession of drug paraphernalia, with a penalty ranging from 6 months and 1 day to 4 years in prison plus a fine of P10,000.00.
      • Conviction in Criminal Case No. C-3533 for illegal sale of shabu, resulting in a sentence of life imprisonment plus a fine of P500,000.00.
      • Acquittal in Criminal Case No. C-3524 for maintaining a drug den.
    • Court of Appeals (CA) Decision
      • On June 30, 2015, the CA affirmed the RTC’s rulings, finding that the evidence established the elements of the crimes charged.
      • The CA held that the apprehending officers had complied with the mandatory chain-of-custody requirements under Section 21, Article II of RA 9165 despite minor deviations.
    • Appeal and Ultimate Resolution
      • Ching elevated his case on appeal, challenging the integrity of the chain-of-custody and alleging defensive claims such as denial and a frame-up by the police.
      • The Supreme Court eventually reviewed the entire record on appeal.

Issues:

  • Sufficiency of Evidence
    • Whether the State was able to establish beyond reasonable doubt that Ching’s possession, sale, and associated actions concerning dangerous drugs satisfied the elements of the offenses charged.
  • Chain-of-Custody and Evidentiary Integrity
    • Whether lapses in the apprehending officers’ compliance with the procedural requirements of Section 21, Article II of RA 9165—including the absence of photographic evidence, inventory in the presence of independent witnesses, and delayed delivery to the crime laboratory—compromised the integrity and evidentiary value of the seized drugs and paraphernalia.
  • Impact of Procedural Lapses
    • Whether deviations from the prescribed chain-of-custody procedures, if justified by field conditions and adequately explained by the state, could still allow the evidence to be admitted and sustain a conviction.
  • Adequacy of Police Testimony
    • Whether the testimony of the apprehending officers, particularly regarding the marking and handling of the seized items, was sufficient to dispel any reasonable doubts concerning the identity and continuity of the evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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