Case Digest (G.R. No. 241067)
Facts:
People of the Philippines v. Eduardo Manansala y Pabalan, G.R. No. 228825, July 28, 2020, Supreme Court First Division, Reyes, J. Jr., J., writing for the Court. The appeal resolved whether accused-appellant Eduardo Manansala y Pabalan (also known as "Eddie") was guilty beyond reasonable doubt of illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165.
The prosecution (the People of the Philippines) charged accused-appellant before the Regional Trial Court (RTC), Branch 57, Angeles City, with selling two paper wrappers each containing plastic sachets of dried marijuana fruiting tops, alleged total weight 6.4380 grams, to a confidential informant (CI) on July 21, 2008. On arraignment he pleaded not guilty and trial followed.
According to the prosecution’s account, a buy-bust team led by Police Senior Inspector Melencio Santos conducted the sting: the CI, accompanied by Senior Police Officer 1 Tomas Nachor, Jr. (SPO1 Nachor), approached accused-appellant who allegedly handed the paper wrapper in exchange for buy-bust money; SPO1 Nachor signaled, backup effected the arrest, the CI turned over the sachets to SPO1 Nachor, the items were inventoried at the police station and later tested positive for marijuana by the crime laboratory.
Accused-appellant testified he was seized unawares while at his tricycle repair/store, was taken and bodily searched, shown alleged seized items, denied selling drugs, and claimed he was unable to identify anyone who could vouch for him.
The RTC, in a Decision dated December 16, 2014, found the prosecution proved the elements of illegal sale beyond reasonable doubt and, despite noting noncompliance with the three‑witness inventory rule in Section 21, Article II of R.A. No. 9165, concluded the chain of custody remained unbroken; it sentenced accused-appellant to life imprisonment and imposed a P500,000 fine. Accused‑appellant appealed to the Court of Appeals.
The Court of Appeals, in a Decision dated June 14, 2016 (CA‑G.R. CR‑HC No. 07304), affirmed the RTC "in toto," agreeing that the chain of c...(Subscriber-Only)
Issues:
- Did the prosecution comply with, or satisfactorily justify deviation from, the mandatory inventory and three‑witness requirement under Section 21, Article II of R.A. No. 9165, such that the chain of custody over the seized drugs was preserved?
- If not, was the prosecution able to prove beyond reasonable doubt the elements of illegal sale under Section 5, Article II of R.A. No. 9165 (identity of buyer/seller, object and consideration, delivery and payment) despite the Se...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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