Case Digest (G.R. No. 229680)
Facts:
People of the Philippines v. Michael Goyena y Abraham, G.R. No. 229680, June 06, 2019, the Supreme Court First Division, Del Castillo, J., writing for the Court.The respondent in the criminal information was Michael Goyena y Abraham (appellant), charged by the prosecution with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002) in an Information dated November 29, 2012. The information alleged that on November 28, 2012, in Legazpi City, appellant knowingly sold to a PDEA poseur-buyer a heat-sealed plastic sachet containing methamphetamine hydrochloride (shabu) weighing 0.301 gram in consideration of P500.00.
At arraignment on December 20, 2012, appellant pleaded not guilty and trial followed. The prosecution's case was that a PDEA Special Enforcement Team received information from a confidential informant that appellant and his sister Cyramil were selling drugs; the CI arranged a buy-bust with Cyramil, who said appellant would meet the buyer. Agent Jonathan Ivan Revilla acted as poseur-buyer. At the operation on November 28, 2012, appellant allegedly approached Agent Revilla, handed him a heat-sealed sachet of shabu, received the marked P500 and boodle money, whereupon a pre-arranged signal was given and the arrest followed. Agent Revilla marked the sachet on the scene (“JIR-11/28/12”), inventory and photographs were taken at the station in the presence of civilian and DOJ witnesses, and the specimen was brought the same day to the PNP regional crime laboratory and tested positive for methamphetamine hydrochloride (Chemistry Report No. D-173-2012).
Appellant denied the charges at trial, testifying that he was playing gambling games when several men accosted and handcuffed him, that evidence was planted into his pocket, and that he was arrested for illegal gambling; he denied having sold shabu. The trial court, Regional Trial Court (RTC), Branch 4, Legazpi City, found the prosecution witnesses credible and convicted appellant in a Judgment dated November 3, 2014, sentencing him to life imprisonment and a P1,000,000 fine. The Court of Appeals (CA) affirmed the RTC in a Decision dated January 15...(Subscriber-Only)
Issues:
- Was appellant’s warrantless arrest illegal, thereby rendering the seized evidence inadmissible as fruits of the poisonous tree?
- Was the integrity and identity (chain of custody) of the seized shabu sufficiently preserved so as to admit...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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