Case Digest (G.R. No. 205889)
Facts:
People of the Philippines v. Sander Dacuma y Lunsod, G.R. No. 205889, February 04, 2015, First Division, Perez, J., writing for the Court.The prosecution charged Sander Dacuma y Lunsod with illegal sale (Criminal Case No. 4319) and illegal possession (Criminal Case No. 4320) of methamphetamine hydrochloride (shabu) allegedly committed on July 15, 2003; the Informations were filed on September 1, 2003. Dacuma pleaded not guilty on November 10, 2003. The prosecution's witnesses included several police officers (PO2 Cabaltera, PO2 Parena, PO3 Rocha), Forensic Chemist Benjamin A. Cruto, Jr., and Barangay Councilor Allan Lesiguez.
On July 15, 2003, members of the Anti-Illegal Drug Task Force proceeded to Carigara, Leyte, to verify a confidential informant’s report. A buy-bust was arranged: PO2 Cabaltera acted as poseur-buyer with marked money; he and the confidential informant approached the accused, negotiated a P600 sale, and allegedly received four plastic sachets containing white crystalline substance from Dacuma. PO2 Cabaltera signaled, back-up officers arrested Dacuma, and he was brought to the police station. A body search at the station allegedly produced three sachets, the marked money, and a lighter.
Dacuma’s defense was that he accepted four P100 bills from his friend Edwin Lagera to buy shabu on Lagera’s behalf, intending to return the money; he claimed police officers later accosted and handcuffed him. Lagera corroborated this version at trial.
The Regional Trial Court (Branch 13, Carigara, Leyte), presided by Presiding Judge Crisostomo L. Garrido, rendered judgment on September 17, 2004: it convicted Dacuma of illegal sale under Section 5 of R.A. No. 9165 and sentenced him to life imprisonment and a P500,000 fine, but dismissed the illegal possession charge for insufficiency of evidence. The Court of Appeals, in CA G.R. CEB CR-HC No. 00558, affirmed the RTC decision in a December 24, 2011 ruling (penned by Associate Justice Myra V. Garcia-Fernandez, with Antonio-Valenzuela and Paredes concurring).
The case was brought to the Supreme Court as an appeal from the Court of Appeals’ decision. On review, the Supreme Court examined the elements of illegal sale and the chain-of-custody requirements under R.A. No...(Subscriber-Only)
Issues:
- Did the prosecution prove beyond reasonable doubt that an illegal sale of dangerous drugs was committed by the accused?
- Were the chain-of-custody requirements (including marking and inventory) under Section 21 of R.A. No. 9165 and its IRR complied with so that the seized items presented in court were properly identified as the same arti...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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