Case Digest (G.R. No. 208095)
Facts:
People of the Philippines v. Jefferson Del Mundo y Abac and Mitos Lacson-Del Mundo, G.R. No. 208095, September 20, 2017, Supreme Court Third Division, Martires, J., writing for the Court.The respondents below and accused-appellants were Jefferson Del Mundo y Abac (Jefferson) and his wife Mitos Lacson-Del Mundo (Mitos). They were indicted in two Informations under R.A. No. 9165: Criminal Case No. CR-05-8045 charged both Jefferson and Mitos with illegal sale of methamphetamine hydrochloride (shabu), and Criminal Case No. CR-05-8046 charged Jefferson with illegal possession of shabu. At arraignment both pleaded not guilty and the cases were consolidated for trial.
The prosecution presented a buy-bust narrative: local police intelligence conducted surveillance and designated Police Officer 3 Mariel D. Rodil (PO3 Rodil) as poseur-buyer; Senior Police Officer 2 Eduardo Espiritu (SPO2 Espiritu) led the team and SPO1 Noel Buhay (SPO1 Buhay) and others served as backups. On 10 May 2005 PO3 Rodil allegedly handed marked money to Mitos, who called to Jefferson inside the house; Jefferson allegedly handed a sachet to PO3 Rodil, who signaled the team. The police arrested the couple and, while apprehending Jefferson, recovered four sachets from a toilet bowl. The seized sachets were photographed, inventoried and marked (one sachet “YEL” and four others “MDR1–MDR4”), and sent to the crime laboratory; forensic tests later yielded positive qualitative results for methamphetamine hydrochloride. Urine tests for both accused were also positive.
The defense presented Jefferson and Mitos who denied the prosecution’s account, claimed force and a frame-up, and asserted that police had already entered and searched their house when Jefferson came out from the comfort room. They testified police beat and dragged Jefferson out and that the search lasted about half an hour.
The Regional Trial Court (RTC), Branch 39, Calapan City, in a 17 May 2011 Joint Decision convicted Jefferson of illegal sale (CR-05-8045) and illegal possession (CR-05-8046) and convicted Mitos of illegal sale (CR-05-8045), imposing life imprisonment and fines for sale and an indeterminate term and fine for possession; the RTC found the police witnesses credible and rejected the defense as mere denial. The accused-appellants appealed to the Court of Appeals (CA).
...(Pro-only)Issues:
- Did the trial court and the Court of Appeals err in convicting the accused-appellants when the prosecution allegedly failed to prove their guilt beyond reasonable doubt?
- Was the chain of custody properly established and the corpus delicti sufficiently presented for Criminal Case No. CR-05-8045 (illegal sale)?
- Was the chain of custody properly established for Criminal Case No....(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)