Case Digest (G.R. No. 226485) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippines v. Bernie Delociembre y Andales and Dhats Adam y Danga (G.R. No. 226485, June 6, 2018), the accused-appellants Bernie Delociembre and Dhats Adam Danga were charged by Information dated April 12, 2010 in RTC, Quezon City, Branch 78, with violation of Section 5, Article II of Republic Act No. 9165 (Illegal Sale of Dangerous Drugs). On April 7, 2010, a PDEA buy-bust team, led by SOII Christopher Macairap with IO1 Junef Avenido as poseur-buyer and IO1 Renata Reyes, effected a sting operation in NIA Road, Quezon City. The informant introduced Avenido to the appellants, who delivered five heat-sealed sachets of a white crystalline substance later confirmed by the PDEA laboratory as methamphetamine hydrochloride (“shabu”). The seized items were marked and inventoried at the PDEA office before Barangay Kagawad Jose Ruiz, Jr. and the accused-appellants, then submitted for forensic examination. Both appellants denied involvement, alleging that they were ar Case Digest (G.R. No. 226485) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Buy-Bust Operation
- On April 7, 2010, an Information was filed in RTC-Quezon City (Branch 78, Crim. Case No. Q-10-163376) charging accused-appellants Bernie Delociembre y Andales and Dhats Adam y Danga with Illegal Sale of Dangerous Drugs (5 transparent sachets of white crystalline substance containing 21.4129 g of methamphetamine hydrochloride).
- A PDEA buy-bust team (SOII Christopher Macairap, IO1 Junef Avenido, IO1 Renata Reyes) conducted a sting:
- An informant arranged to purchase 25 g of shabu for ₱150,000 from “Axe” (Bernie).
- At NIA Road, Dhats handed a cardboard containing the substance to IO1 Avenido, who paid Benny; the signal was executed and both were arrested.
- Seized items were marked and inventoried at the PDEA office in the presence of Barangay Kagawad Jose Ruiz, Jr. and the accused; photographs were taken; laboratory examination confirmed methamphetamine hydrochloride and meferonex.
- Defenses of the Accused
- Bernie’s Defense of Denial and Alibi
- Claimed he was at home at noon preparing his son for school when PDEA agents came asking for “Axe,” invited him to PDEA office, saw drugs for the first time there, then taken for inquest.
- Dhats’s Defense of Denial and Alibi
- Asserted he was at home with his wife, was seized by six armed men, brought to PDEA office then Camp Crame, allegedly asked to pay ₱100,000, and later taken for inquest.
- Judicial Proceedings
- RTC Judgment (Dec. 12, 2014): Convicted under Sec. 5, Art. II, RA 9165; imposed life imprisonment and ₱500,000 fine. Found sale proven, positive identification, and lab results; defenses unsubstantiated.
- CA Decision (Mar. 31, 2016): Affirmed RTC. Held chain of custody intact; marking at PDEA justified due to Muslim compound crowd; absence of DOJ rep excused by presence of barangay official.
- SC Resolution (Apr. 17, 2017): Affirmed CA decision. Accused-appellants filed Motion for Reconsideration (July 20, 2017), urging non-compliance with Sec. 21, Art. II of RA 9165.
Issues:
- Did the prosecution comply with Section 21, Article II of RA 9165 regarding physical inventory and photography in the presence of required witnesses?
- Were the failure to secure representatives of the media and the Department of Justice justifiable under the IRR and RA 10640?
- Did procedural lapses compromise the chain of custody and the integrity and evidentiary value of the seized drugs, thereby undermining proof beyond reasonable doubt?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)