Title
People vs. Climaco
Case
G.R. No. 199403
Decision Date
Jun 13, 2012
Appellant acquitted due to broken chain of custody; prosecution failed to prove guilt beyond reasonable doubt in illegal drug sale and possession case.

Case Digest (G.R. No. 199403)
Expanded Legal Reasoning Model

Facts:

  • Consolidated Criminal Case
    • The case involves charges against Gomer S. Climaco for violations of Sections 5 and 11 of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002) on counts of illegal possession and illegal sale of methamphetamine hydrochloride (shabu).
    • Two criminal cases were filed: Criminal Case No. 4911-SPL for illegal possession and Criminal Case No. 4912-SPL for illegal sale.
    • The Regional Trial Court (RTC) of San Pedro, Laguna, Branch 31 rendered a decision on January 20, 2009, convicting Climaco on both counts with corresponding prison terms and fines.
    • The Special Fifteenth Division of the Court of Appeals (CA) affirmed the RTC’s decision on March 29, 2011.
  • Prosecution’s Version of Events
    • The buy-bust operation was conducted by police officers including PO1 Alaindelon M. Ignacio, SPO3 Samson, SPO4 Balverde, SPO4 Almeda, and others.
      • PO1 Ignacio, assigned to the Intelligence Division of the San Pedro Municipal Police Station, acted as the poseur-buyer.
      • During the operation on September 7, 2004, the team executed a buy-bust transaction at a location identified as Climaco’s residence.
    • Testimony and Documentary Exhibits
      • PO1 Ignacio testified he approached Climaco, who then presented shabu and accepted money in a staged sale.
      • After the transaction, police recovered two plastic sachets—one from the buy-bust operation and another directly from Climaco.
      • The recovered items were marked and labeled by SPO4 Teofilo Royena (with markings TR-B for the buy-bust and TR-R for the recovered item).
      • Documentary exhibits included:
        • Exhibit aAa – a written request for laboratory examination.
ii. Exhibit aBa – Chemistry Report No. D-1102-04. iii. Exhibit aCa – one-half white envelope. iv. Exhibit aC-1a and aC-2a – plastic sachets with alleged markings indicating their chain of custody.
  • The forensic chemist’s report, however, identified the sachets with different markings: aGSC-1a and aGSC-2a.
  • Defense’s Version of Events
    • Appellant Climaco, along with his wife and other witnesses, testified that he was a victim of an unauthorized frisking and arrest by unidentified armed men.
    • Climaco claimed that on the day of the incident, while he was with his immediate family at home, armed men forcibly raided his residence.
    • He denied any involvement in the sale or possession of shabu and stated that he was not aware of being on any watch list of illegal drug pushers.
    • Other defense witnesses (Michael M. Basihan and Cristina Gamboa Climaco) corroborated the absence of any drug sale or possession by describing the events prior to, during, and after the alleged buy-bust operation, emphasizing inconsistencies in the police procedure.
  • Trial Court and Appellate Decisions
    • The RTC found Climaco guilty beyond reasonable doubt in both cases, basing its rulings on the testimonies (notably that of PO1 Ignacio) and the documentary evidence presented by the prosecution.
    • The RTC noted that Climaco’s defense of a frame-up was unconvincing.
    • The CA affirmed the RTC’s conviction, emphasizing that all elements of the crimes were sufficiently established, including the unbroken chain of custody as testified by PO1 Ignacio.
  • Discrepancies in Evidence Handling
    • The crux of the matter arose from the conflicting markings on the plastic sachets.
      • PO1 Ignacio testified that the sachets recovered bore the identifications aTR-B (from the buy-bust) and aTR-R (from the direct recovery from Climaco).
      • Conversely, the Chemistry Report and other ancillary exhibits clearly showed the markings as aGSC-1a and aGSC-2a.
    • This inconsistency raised significant doubts about the chain of custody and the integrity of the evidence submitted to the trial court.

Issues:

  • Whether the prosecution established beyond reasonable doubt that Climaco was guilty of the crimes of illegal sale and illegal possession of shabu.
    • Central to this issue is the question of whether the evidence truly linked Climaco to the dangerous drug, given the discrepancies in the labeling of the recovered drug samples.
    • Whether the chain of custody, a requisite for proving the identity and integrity of the dangerous drug (corpus delicti), was preserved without tampering or substitution.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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