Case Digest (G.R. No. 240922)
Facts:
People of the Philippines v. Patricio Honasan y Grafil, G.R. No. 240922, August 07, 2019, Supreme Court Third Division, Inting, J., writing for the Court. The appellant, Patricio Honasan y Grafil, was charged in three consolidated cases arising from operations conducted on July 27–28, 2010: Criminal Case No. 10-1193 (illegal possession, Sec. 11, Art. II, R.A. No. 9165), Criminal Case No. 10-1194 (sale by co-accused Noel Carpio and Bonifacio Oseo), and Criminal Case No. 10-1195 (illegal sale, Sec. 5, Art. II, R.A. No. 9165). The incidents involved a test-buy and a buy-bust operation conducted by PDEA and police operatives in Zone 8, Bulan, Sorsogon.The prosecution presented operatives (including I01 Arnel Estrellado and I01 Reynaldo Benzon) and a PNP forensic chemist who testified that marked sachets tested positive for methamphetamine hydrochloride. The prosecution’s narrative was that during the buy-bust the poseur-buyer received two sachets (one from Bonifacio as the “responde” and one from appellant) in exchange for marked buy-bust money; photographs and an inventory were taken and the seized items were brought to the crime laboratory for examination. The defense produced witnesses (including appellant and his nephew Alfel Golloso) who described a drinking group, an altercation, and a subsequent arrest by PDEA operatives; appellant denied selling or receiving money and argued procedural lapses in the handling of evidence.
The Regional Trial Court (Branch 65, Sorsogon City) in a Decision dated December 9, 2016 convicted appellant of both illegal possession (Crim. Case No. 10-1193) and illegal sale (Crim. Case No. 10-1195), sentenced him accordingly, ordered confiscation of the drugs, and directed an alias warrant for Bonifacio; Noel Carpio was acquitted. On appeal, the Court of Appeals in a February 22, 2018 decision affirmed the RTC verdict with modification (reduction of fines), holding appellan...(Subscriber-Only)
Issues:
- Did the prosecution substantially comply with the chain of custody and inventory requirements of Section 21, paragraph 1, Article II of R.A. No. 9165 such that the seized drugs retained evidentiary integrity?
- Did the prosecution prove beyond reasonable doubt that appellant was the seller/possess...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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