Case Digest (G.R. No. 234156)
Facts:
People of the Philippines v. Emmanuel Oliva y Jorjil, Bernardo Barangot y Pilais and Mark Angelo Manalastas y Gapasin, G.R. No. 234156, January 07, 2019, Supreme Court Third Division, Peralta, J., writing for the Court.
The prosecution (People of the Philippines) charged Emmanuel Oliva (appellant), Bernardo Barangot (appellant) and Mark Angelo Manalastas (appellant) with violation of Sections 5 and 11, Article II of Republic Act No. 9165 (illegal sale and illegal possession of dangerous drugs) arising from a buy‑bust operation in Makati City in January 2015. The SAID‑SOTG received a report on January 23, 2015 about a seller known as “Manu”; a buy‑bust team with PO3 Luisito Marcelo as poseur‑buyer was formed and given marked money.
At the target area the confidential informant identified appellant Oliva as “Manu.” PO3 Marcelo, introduced as a buyer, handed marked money to Oliva, who displayed four transparent sachets of white crystalline substance; Marcelo and the two other persons (appellants Barangot and Manalastas) each took one sachet. Marcelo gave the pre‑arranged chin signal; he and other operatives arrested Oliva, Barangot and Manalastas. A body search of Oliva produced another sachet, the marked P500 bill and two additional P500 bills. The arrestees were taken to the barangay hall where an inventory was prepared; the seized items were marked, photographed and submitted to the PNP Crime Laboratory, which tested positive for methamphetamine hydrochloride.
An Information for illegal sale (Crim. Case No. 15‑195) was filed against Oliva; separate Informations for illegal possession were filed against Oliva (Crim. Case No. 15‑196), Barangot (Crim. Case No. 15‑197) and Manalastas (Crim. Case No. 15‑198). All pleaded not guilty and asserted denials and alibis (each claiming unlawful or earlier detention by armed men and transfer to SAID‑SOTG custody).
The Regional Trial Court (RTC), Branch 65, Makati City, found the appellants guilty beyond reasonable doubt: Oliva was convicted of illegal sale (life imprisonment and P500,000 fine) and all three appellants were convicted of illegal possession (12 years and one day to 14 years and eight months, and P300,000 fine each). The RTC ordered disposition of the seized drugs and transmission of the sachets to PDEA.
The Court of Appeals (CA) affirmed the RTC “in toto,” holding that the prosecution established the elements of the offenses and that the failure to show full compliance with the physical inventory and photographing requirements did not ipso fa...(Pro-only)
Issues:
- Did the prosecution satisfactorily prove a justifiable ground for noncompliance with Section 21 of R.A. No. 9165 and its IRR as amended by R.A. No. 10640?
- Did the alleged shortcomings in inventory, marking and witnessing render the seized drugs inadmissible or break the chain of custody?
- Did the prosecution prove the elements of illegal sale (Section 5) and illegal possession (Section 11) of d...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)