Case Digest (G.R. No. 234773)
Facts:
The People of the Philippines v. Almaser Jodan y Amla, G.R. No. 234773, June 03, 2019, Supreme Court Third Division, Peralta, J., writing for the Court.In January 2008 an Information was filed charging Almaser Jodan y Amla with violation of Section 5, Article II of R.A. No. 9165 for allegedly selling 0.03 gram of methylamphetamine hydrochloride ("shabu") on October 4, 2007 in Quezon City. Appellant pleaded not guilty; pre-trial and trial followed in the Regional Trial Court (RTC), Quezon City, Branch 78.
The prosecution's witnesses—PO3 Leonardo Ramos, Jr., PO1 Alexander Jimenez, PO1 Teresita B. Reyes, and Police Chief Inspector Bernardino Banac, Jr.—described a buy-bust operation initiated after a confidential informant's tip. PO1 Reyes acted as the poseur-buyer, who purportedly bought P200.00 worth of shabu from appellant; she executed the prearranged signal, after which operatives arrested appellant and recovered the marked buy-bust money and additional sachets. Inventory receipts were prepared at the scene and the seized specimens were later sent to the crime laboratory via PO2 Ortiz; Chemistry Report No. D-345-07 confirmed the presence of methamphetamine hydrochloride.
Appellant denied the charge, testifying that police officers forcibly entered his home, handcuffed and detained him, took him to the precinct, extorted money and later lodged him for inquest. He claimed the police were strangers to him and that the inventory was not properly conducted.
On June 19, 2015 the RTC found the prosecution proved both the sale and the corpus delicti, upheld the integrity of the seized drugs (noting marking at the scene and subsequent chemical confirmation), convicted appellant of illegal sale of dangerous drugs, sentenced him to life imprisonment and fined him Php500,000.00, and ordered transmission of the drugs to PDEA for disposition.
Appellant appealed to the Court of Appeals (CA). On June 30, 2017 the CA, in CA-G.R. CR-HC No. 08262, affirmed the RTC Judgment, holding that the chain of custody remained intact despite the non-presentation of the desk officer because the prosecutio...(Pro-only)
Issues:
- Did the prosecution sufficiently comply with Section 21, Article II of R.A. No. 9165 and Section 21(a) of the IRR to establish an unbroken chain of custody of the seized drugs?
- If not, does the prosecution's failure warrant reversal and acquittal for failure to prove guilt be...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)