Title
People vs. De Lumen y Ladlagaran
Case
G.R. No. 240749
Decision Date
Dec 11, 2019
The Supreme Court acquitted Giovanni de Lumen y Ladlagaran in a drug possession case due to significant breaches of the chain of custody rule, undermining the integrity of the evidence.
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Case Digest (G.R. No. 240749)

Facts:

  • Giovanni de Lumen y Ladlagaran (appellant) and Maura Aranzaso y Mendoza (co-accused) were involved in a criminal case for violating the Comprehensive Dangerous Drugs Act of 2002 (Republic Act No. 9165).
  • The incident occurred on September 11, 2009, in General Trias, Cavite, during a buy-bust operation initiated by Police Officer II Victor O. Tampis (PO2 Tampis) due to complaints about Maura's illegal drug activities.
  • A concerned citizen reported Maura's drug trade, prompting her to be placed on the police watch list.
  • PO2 Tampis, acting as a poseur-buyer, purchased a plastic sachet of suspected shabu from Maura.
  • Following the transaction, police arrested Maura and found Giovanni and Arcangel Lapiz using illegal drugs in Maura's residence.
  • Various drug paraphernalia, including aluminum foil, lighters, and plastic sachets, tested positive for methamphetamine hydrochloride.
  • The Regional Trial Court (RTC) of Trece Martires City, Cavite, found both guilty; Giovanni received imprisonment and a fine, while Maura was sentenced to reclusion perpetua and a hefty fine.
  • Both accused appealed, leading to the Court of Appeals (CA) upholding Giovanni's conviction but acquitting Maura on reasonable doubt.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the Court of Appeals' decision regarding Giovanni de Lumen, acquitting him of the charges for violating Section 12, Article II of Republic Act No. 9165.
  • The Court determined that the prosecution failed to establish a proper chain o...(Unlock)

Ratio:

  • The Supreme Court underscored the critical role of the chain of custody in drug-related cases to ensure the authenticity and integrity of evidence presented in court.
  • The prosecution must provide a clear account of the handling of seized items from seizure to court presentation.
  • In this case, the prosecution did not c...continue reading

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