Case Digest (G.R. No. 140848)
Facts:
People of the Philippines v. Crispin Mamuyac, Jr., G.R. No. 234035, August 19, 2019, Supreme Court Second Division, Carpio, Acting C.J., writing for the Court. The appellant is Crispin Mamuyac, Jr. y Palma; the appellee is the People of the Philippines. The case arose from Criminal Case No. 2194-19 before the Regional Trial Court (RTC), First Judicial Region, Branch 19, Bangui, Ilocos Norte.On April 2, 2014, an Information charged appellant with unlawful sale of methamphetamine hydrochloride (shabu) in violation of Section 5, Article II of Republic Act No. 9165. The parties stipulated appellant was at his house in Brgy. Estancia, Pasuquin, Ilocos Norte at about 7:30 p.m. on the day in question and agreed the central issue would be the legality of the arrest arising from a buy-bust operation. Appellant pleaded not guilty.
The prosecution presented testimony of the police poseur-buyer PO1 Alexson Rosal and other PNP officers who narrated a buy-bust operation based on a confidential informant’s tip, the exchange of a marked P500 bill for a heat-sealed sachet, appellant’s flight and surrender, marking of the sachet at the police station (“CPM1”), inventory and photographs, turnover to the crime laboratory, and a chemistry report confirming methamphetamine hydrochloride (0.0343 gram). The prosecution introduced a joint affidavit, police blotter extracts, coordination and pre-operational reports, chemistry reports and logbooks, pictures, inventory, the specimen, and the buy-bust money (CA-G.R. CR-H.C. No. 07746 exhibits A–M).
Appellant testified denying the sale and describing forcible removal from his house; his wife’s testimony was stipulated; Barangay Chairman Precidio Caliva Palalay, called hostile by the prosecution, later disclaimed recollection of the certification and denied signing the inventory receipt. The RTC, in a Decision dated August 17, 2015, convicted appellant and sentenced him to life imprisonment with fine, ruling the buy-bust and arrest legal and finding the chain of custody sufficiently preserved despite inventory and marking being made at the police station.
The Court of Appeals affirmed in a Decision promulgated November 7, 2016 (CA-G.R. CR-H.C. No. 07746). The Public Attorney’s Office filed a notice of appeal; the Solicitor General and the PAO filed manifestations in lieu of supplemental briefs. The appeal reached the Supreme Court challenging, p...(Subscriber-Only)
Issues:
- Did the prosecution comply with the chain of custody requirements prescribed by Section 21 of RA 9165 and its Implementing Rules and Regulations?
- Do the identified lapses (marking and inventory at the police station, absence/refusal of barangay signatures, the sachet being carried in the poseur-buyer’s pocket, and testimonial inconsistencies) create reasonable doubt that requires acquittal?
- Was the buy-bust operation and arrest legally valid and did the prosecution other...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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