Title
People vs. Mariano
Case
G.R. No. 247522
Decision Date
Feb 28, 2022
A buy-bust operation led to Nora's arrest for illegal drug sale and possession, but the Supreme Court acquitted her due to broken chain of custody and procedural lapses under RA 9165.
A

Case Digest (G.R. No. L-62243)

Facts:

  • Operative Facts
    • On August 6, 2011, a confidential informant (CI) alerted PO3 Lendro Tutor of Nora’s alleged sale of shabu in front of NCCC Supermarket, Davao City.
    • A buy-bust team was formed: PO3 Tutor as poseur-buyer with a marked ₱1,000 bill; PO2 Arubio and PO1 Acierto as back-up.
    • The CI identified Nora; Tutor signaled after the marked money-sachet exchange; Nora and co-accused were arrested.
    • Search of Nora recovered one large sachet (1.0923 g) and forty smaller sachets (3.5437 g total), plus ₱10,150 in cash.
  • Inventory, Laboratory Examination and Procedural History
    • Inventory and photographs conducted on August 8, 2011 in presence of Nora, a media representative, Barangay and DOJ officials.
    • Seized items submitted to PNP Crime Lab; PSI Fabian’s Chemistry Report No. D-128-11 confirmed methamphetamine hydrochloride.
    • Two Informations filed: Criminal Case No. 70,390-11 (Illegal Sale of 0.1569 g) and No. 70,389-11 (Illegal Possession of 4.6360 g). Nora pleaded not guilty and testified to an alibi; her drug test was negative.
    • RTC (March 21, 2017) convicted Nora of both charges; CA (August 16, 2018) affirmed with penalty modification. Nora appealed to the Supreme Court.

Issues:

  • Whether the prosecution proved the elements of Illegal Sale of Dangerous Drugs beyond reasonable doubt.
  • Whether the prosecution proved the elements of Illegal Possession of Dangerous Drugs beyond reasonable doubt.
  • Whether the chain of custody and the requirements of Section 21, Article II, RA 9165 (and its IRR) were observed to preserve the identity and integrity of the seized drugs.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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