Case Digest (G.R. No. 243664)
Facts:
The case involves Jocel BaAares De Dios, also known as "Tata," who is the accused-appellant in a drug-related offense. On June 5, 2014, members of the Tabaco City Police Station, equipped with a confidential informant, conducted a buy-bust operation against the accused. This operation led to the recovery of one heat-sealed plastic sachet containing 0.024 grams of white crystalline substance, later identified as methamphetamine hydrochloride. The police first apprehended the accused after the sale of the sachet to a poseur-buyer, Police Officer 3 Benedict Codia, and subsequently found two additional sachets in a pouch during a search.The arrest and seizure followed the procedures outlined by law, including the marking, inventory, and photography of the seized items, with the presence of key witnesses from the media, the Department of Justice, and local barangay officials. The chain of custody for the drug evidence was upheld as the items were submitted to the forensic chemist
Case Digest (G.R. No. 243664)
Facts:
- Case Background and Charges
- The case involves two Informations filed before the Regional Trial Court (RTC) of Tabaco City, Branch 18.
- Accused-appellant Jocel Baaares De Dios, also known as "Tata," was charged with:
- Illegal Sale of Dangerous Drugs under Section 5, Article II of RA 9165.
- Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165.
- The Buy-Bust Operation and Seizure of Evidence
- On June 5, 2014, members of the Tabaco City Police Station, assisted by a confidential informant, conducted a successful buy-bust operation against the accused.
- During the operation:
- A heat-sealed plastic sachet containing 0.024 gram of a white crystalline substance was recovered from the accused.
- A subsequent search led to the seizure of a pouch containing two additional heat-sealed plastic sachets of suspected shabu.
- The seized items were immediately processed:
- The police officer conducted the marking, inventory, and photography of the items at the place of apprehension.
- Witnesses present during the evidence processing included:
- Media Representative Rodel B. Brotamonte.
- Department of Justice (DOJ) Representative Romulo B. Barbacena.
- Barangay Official Elmer U. Gascon.
- The accused-appellant himself.
- The items were then transferred to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
- The Accused’s Defense and Allegations
- Accused-appellant denied the charges, claiming that:
- At the time of the incident, he was waiting for a pedicab along Riosa Street, Tabaco City.
- Police Officer 3 Benedict Codia suddenly apprehended and handcuffed him.
- He further alleged:
- That at the police station, police officer PO1 Chona Cea allegedly delivered to PO3 Codia a paper wrapped in a ₱500.00 bill containing three sachets of shabu.
- That the items were planted and that his arrest was motivated by prior arrest for theft, from which he was later released due to lack of evidence.
- Trial Court Proceedings and Rulings
- On August 1, 2016, the RTC found the accused guilty beyond reasonable doubt for both charges.
- The sentencing was specified as follows:
- In Criminal Case No. T-5869 (Illegal Sale of Dangerous Drugs): Life imprisonment plus a fine of ₱500,000.00.
- In Criminal Case No. T-5870 (Illegal Possession of Dangerous Drugs): Imprisonment for an indeterminate period of 12 years and 1 day (minimum) to 14 years (maximum) plus a fine of ₱300,000.00.
- The RTC held that the prosecution had established all elements of the crimes through clear and convincing evidence, particularly emphasizing the integrity of the chain of custody.
- The Court of Appeals and the Final Appeal
- Accused-appellant challenged the RTC’s decision by appealing to the Court of Appeals (CA).
- On May 23, 2018, the CA affirmed the RTC’s ruling in toto, supporting the proper handling of evidence and the factual findings regarding the accused’s guilt.
- The accused's appeal further contended that the procedures surrounding the chain of custody might have been breached, thereby questioning the integrity of the evidence.
Issues:
- Whether the prosecution successfully established all the elements required to convict the accused of Illegal Sale and Illegal Possession of Dangerous Drugs.
- Did the evidence demonstrate beyond reasonable doubt that the accused engaged in a buy-bust operation involving the sale of dangerous drugs?
- Was it sufficiently proven that the accused was in free and conscious possession of the seized dangerous drugs?
- Whether the chain of custody for the seized evidence complied with the requirements of RA 9165.
- Were the procedures involving marking, inventory, and photography of the seized items properly observed and documented?
- Did the presence of the required witnesses during the evidence handling process effectively eliminate any suspicion of evidence tampering, mixing, or planting?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)