Case Digest (G.R. No. 192231)
Facts:
People of the Philippines v. James Galido y Noble, G.R. No. 192231, February 13, 2013, the Supreme Court Second Division, Perez, J., writing for the Court. The appeal arose from a buy‑bust operation and subsequent criminal prosecution for sale and possession of dangerous drugs under R.A. No. 9165.The petitioner in the criminal prosecution was the People of the Philippines (plaintiff‑appellee); the accused‑appellant was James Galido y Noble. The buy‑bust operation occurred on November 5, 2003 at about 6:00 p.m., conducted by members of the Makati Anti‑Drug Abuse Council (MADAC) and the Anti‑Illegal Drug Special Operation Task Force (AIDSOTF) after an informant notified Punong Barangay Rodolfo Doromal. SPO4 Arsenio Mangulabnan designated PO2 Ruel Antigua to head the operation; Antigua coordinated with the Philippine Drug Enforcement Agency (PDEA) and assigned MADAC operative Roberto Punzalan as the poseur‑buyer, who was given two P100 bills as buy‑bust money.
At the target location in Tanguile St., Brgy. Cembo, Makati City, the informant introduced Punzalan to Galido. According to prosecution testimony, Punzalan handed the money to Galido, who placed it in his right pocket, produced a plastic sachet from his left pocket and gave it to Punzalan; Punzalan then signaled and the arresting team took Galido into custody. After arrest, Herminia Facundo asked Galido to empty his pockets; a second plastic sachet and the buy‑bust money were recovered. Punzalan marked the purchased sachet “JNG” and the sachet taken from Galido “JNG‑1.” Forensic examination was later performed and the specimens tested positive for methamphetamine hydrochloride.
Galido denied the accusations. He testified that men entered his house, frisked him and initially recovered nothing; he was brought to the Barangay Hall where he alleged Doromal showed him a sachet and slapped him. He underwent a drug test that later proved positive. He pleaded not guilty when arraigned.
At pre‑trial the parties stipulated that Forensic Chemist Sharon Lontoc Fabros of the PNP Crime Laboratory examined the submitted samples and they tested positive for methamphetamine hydrochloride. The Regional Trial Court of Makati City, in a decision dated August 4, 2007, convicted Galido of violation of Sections 5 and 11, Article II of R.A. No. 9165, imposing life imprisonment and fines for sale and a separate prison term and fine for possession. The Court of Appeals affirmed the conviction in ...(Pro-only)
Issues:
- Was the prosecution able to prove beyond reasonable doubt that the accused committed illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165?
- Was the prosecution able to prove beyond reasonable doubt that the accused committed illegal possession of dangerous drugs under Section 11, Article II of R.A. No. 9165?
- Was the chain of custody and the evidentiary value of the seized specimens sufficiently established despite the absence o...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)