Title
People vs. De Castro y Santos
Case
G.R. No. 243386
Decision Date
Sep 2, 2019
De Castro acquitted as prosecution failed to prove compliance with chain of custody rules under RA 9165, compromising drug evidence integrity.

Case Digest (G.R. No. 243386)

Facts:

People of the Philippines v. Hilario De Castro y Santos alias "Dacoy", G.R. No. 243386, September 02, 2019, the Supreme Court Second Division, Caguioa, J., writing for the Court.

The accused-appellant was Hilario De Castro y Santos (hereafter “De Castro”); the prosecution was the People of the Philippines. Two Informations charged De Castro with: (1) illegal possession of dangerous drugs (Criminal Case No. 10-501) in violation of Section 11, Article II of R.A. No. 9165 (methylamphetamine hydrochloride, 0.12 gram), and (2) illegal sale of dangerous drugs (Criminal Case No. 10-502) in violation of Section 5, Article II of R.A. No. 9165 (methylamphetamine hydrochloride, 0.02 gram). De Castro pleaded not guilty.

The prosecution’s account, as summarized by the Court of Appeals, described a police-organized buy-bust on 4 August 2010 in Muntinlupa: an informant and PO3 Amodia posed as buyer; after the exchange, PO3 Amodia signaled the transaction, identified himself as a policeman, and the arresting team frisked and recovered the buy-bust money and a yellow plastic container bearing three small heat-sealed sachets. The police marked the container and sachets at the place of arrest, transported the seized items to the CID office, prepared a Certificate of Inventory there after efforts to summon a media/DOJ/elected official failed, and subsequently turned the evidence over to the crime laboratory where forensic testing confirmed methamphetamine hydrochloride. Several police witnesses and documentary exhibits were presented; some testimonies and custody witnesses were stipulations.

De Castro testified as sole defense witness. He denied selling or possessing drugs and asserted that he had been unlawfully picked up earlier (he claimed 3 August 2010) by persons he later saw were policemen; he denied the prosecution’s account of the buy-bust transaction.

The Regional Trial Court (Branch 203, Muntinlupa City) found the prosecution proved the elements of illegal sale and illegal possession beyond reasonable doubt, ruled that the buy-bust was adequately documented and police officers acted within acceptable standards, found the chain of custody intact, and sentenced De Castro to imprisonment and fines (Decision dated November 16, 2015). De Castro appealed to the Court of Appeals.

The Court of Appeals, in a Decision dated February 6, 2018 (CA‑G.R. CR‑HC No. 07962), affirmed the RTC, holding that the elements of the offens...(Pro-only)

Issues:

  • Whether De Castro’s guilt for violating Sections 5 and 11, Article II of R.A. No. 9165 was proven beyond reasonable do...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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