Case Digest (G.R. No. 234821)
Facts:
- Bobby Pacnisen y Bumacas (accused-appellant) was involved in a case against the People of the Philippines (plaintiff-appellee).
- On September 18, 2012, a buy-bust operation was conducted by the Philippine Drug Enforcement Agency (PDEA) in Brgy. Urbiztondo, San Juan, La Union.
- A confidential informant reported Pacnisen's marijuana sales to the PDEA.
- A buy-bust team was formed, including Agent Efren E. Esmin as the poseur buyer, with marked money totaling P6,000.00.
- During the operation, Pacnisen confirmed the availability of marijuana and handed over two bricks in exchange for the marked money.
- The buy-bust team arrested Pacnisen, informed him of his rights, and conducted a body search.
- The seized items were inventoried in the presence of the barangay captain and a media representative.
- Laboratory examination confirmed the substance as a dangerous drug.
- Pacnisen was charged under Section 5, Article II of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002) and pleaded not guilty.
- The Regional Trial Court (RTC) convicted him on March 30, 2016, sentencing him to life imprisonment and a fine of P500,000.00.
- The Court of Appeals (CA) affirmed the RTC's ruling on June 21, 2017, leading to an appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court dismissed the appeal, affirming the RTC and CA's decisions that found Pacnisen guilty beyond reasonable doubt of illegal drug sale.
- The Court confirmed that a legitimate bu...(Unlock)
Ratio:
- The Supreme Court highlighted that the prosecution must prove two essential elements in drug-related cases:
- A transaction involving illegal drugs occurred.
- The corpus delicti (illegal substance) was presented in court.
- The prosecution established both elements through credible testimonies from PDEA agents.
- The Court acknowledged the importance of Section 21 of RA 9165 regarding the inventory of seized items, noting the absence of a DOJ representative.
- The explanation from PDEA agents about the urgency of ...continue reading
Case Digest (G.R. No. 234821)
Facts:
The case involves Bobby Pacnisen y Bumacas (the accused-appellant) and the People of the Philippines (the plaintiff-appellee). The events leading to the case began on September 18, 2012, when a buy-bust operation was conducted by agents of the Philippine Drug Enforcement Agency (PDEA) in Brgy. Urbiztondo, Municipality of San Juan, Province of La Union. A confidential informant reported to the PDEA that Pacnisen was selling marijuana. Following this tip, a buy-bust team was formed, which included Agent Efren E. Esmin as the poseur buyer. The team prepared marked money amounting to P6,000.00, consisting of one genuine P1,000 bill and several boodle money bills.
During the operation, Agent Esmin met with Pacnisen, who confirmed the availability of the marijuana. After a brief negotiation, Pacnisen handed over two bricks of marijuana in exchange for the marked money. The transaction was witnessed by the buy-bust team, and upon completion, the team arrested Pacnisen, informed him of his rights, and conducted a body search. The seized items were inventoried in the presence of the barangay captain and a media representative. The marijuana was later confirmed to be a dangerous drug through a laboratory examination.
Pacnisen was charged with violating Section 5, Article II of Republic Act No. 9165, known as "The Comprehensive Dangerous Drugs Act of 2002." He pleaded not guilty during his arraignment. The Regional Trial Court (RTC) found him guilty on March 30, 2016, sentencing him to li...