Case Digest (G.R. No. 252029) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case revolves around Pablito Pagaspas y Alcantara (Pagaspas) and Joey De Leon y Valeriano (De Leon), accused of the illegal sale and possession of dangerous drugs, specifically methamphetamine hydrochloride, commonly known as "shabu." The events occurred on July 19, 2017, at approximately 3:20 PM in Sitio Palao, Kapayapaan Village, Barangay Canlubang, City of Calamba, Laguna. A buy-bust operation was conducted by a police team comprising Police Officer 1 (PO1) France Yve Male and PO1 Kevin B. Agudo, accompanied by a confidential informant. During the operation, De Leon was the initial point of contact, confirming the presence of Pagaspas, who ultimately completed the illicit drug transaction by selling a plastic sachet of shabu to a poseur buyer. Following the sale, Pagaspas was arrested, and De Leon was subsequently apprehended by PO1 Agudo.Upon arresting Pagaspas, it was revealed that he possessed a black coin purse containing four additional sachets of shabu. Both item
Case Digest (G.R. No. 252029) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal Charges and Allegations
- The accused, Pablito Pagaspas y Alcantara and Joey De Leon y Valeriano, were charged with offenses under Republic Act No. 9165 – the Comprehensive Dangerous Drugs Act of 2002.
- De Leon and Pagaspas were charged with illegal sale of dangerous drugs under Section 5 in relation to Section 26.
- Additionally, Pagaspas faced a separate charge of illegal possession of dangerous drugs under Section 11.
- The Information specified that on or about 3:20 p.m. on July 19, 2017, at Sitio Palao, Kapayapaan Village, Barangay Canlubang, Calamba City, Laguna, the accused allegedly sold a quantity of methamphetamine hydrochloride (“shabu”) with a total weight of 0.06 gram/s, while Pagaspas allegedly possessed four additional plastic sachets weighing 0.22 gram/s.
- Incident and Arrest Details
- A buy-bust operation was conducted targeting a person later identified as Pagaspas.
- The operation involved a team including Police Officer 1 (PO1) Male, PO1 Agudo, a confidential informant, and others.
- Upon arrival at Pagaspas’s residence, the informant and the team initiated the operation by identifying the presence of the accused and setting in motion the procedure to purchase the illegal substance.
- During the operation, a marked P500.00 bill was exchanged.
- De Leon’s interjection and subsequent actions led to the involvement of PO1 Male and PO1 Agudo in arresting Pagaspas and apprehending De Leon.
- The apprehending officer, PO1 Male, conducted a body search and recovered a coin purse containing four additional sachets which were marked accordingly (“FYM-1” to “FYM-4”), alongside the purchased sachet marked “7-19-17 BB-FYM” or a variation thereof.
- Handling of Evidence and Chain of Custody Procedures
- After the arrest, the officer maintained custody of all five suspect sachets by keeping the bought item in his pocket and the others in another pocket until reaching the police station.
- The items were subsequently turned over to the Regional Crime Laboratory Office for examination, where they tested positive for shabu.
- Discrepancies arose regarding the markings on the sachets:
- One document attached to the laboratory examination request showed the marking “7/19/17 BBAFYM” whereas testimonies varied on the use of slashes, hyphens, or missing hyphens in the markings.
- The variations caused doubt about whether proper marking procedures were followed to safeguard the integrity and identity of the evidence.
- Court Proceedings and Testimonies
- At arraignment, both accused pleaded not guilty, leading to a trial on the merits.
- The prosecution relied on testimonies of the buy‐bust team to establish the elements of illegal sale and possession.
- The defense countered with a narrative alleging coercion, framing by the police, and inconsistencies in the account of the arrest and evidence handling.
- The Regional Trial Court rendered a decision on May 3, 2018, convicting:
- Pagaspas for illegal possession with a sentence of imprisonment ranging from 12 years and 1 day to 14 years plus a fine of PHP300,000.00.
- Both accused were convicted for illegal sale and sentenced to life imprisonment plus fines of PHP500,000.00 each.
- The Court of Appeals affirmed the RTC’s decision on June 21, 2019, accepting the prosecution’s narrative and weighing the evidentiary chain of custody as intact, despite noted lapses.
- Evidentiary and Procedural Controversies
- Accused-appellants argued that the arresting officers deviated from the strict requirements of Section 21 of RA 9165, which governs the custody and disposition of seized items.
- They stressed that the failure to properly mark, inventory, and secure the evidence raised doubts as to whether the integrity and identity of the corpus delicti were preserved.
- The prosecution maintained that the chain of custody was unbroken and that any lapses were nonfatal as long as the integrity of the evidence was maintained.
- Key discrepancies identified included:
- Differences in the markings on the seized plastic sachet(s).
- Gaps in the narrative regarding the exact manner of handling the evidence, including unclear transitions between custody by the arresting officer and any investigating officer.
- Final Judicial Determination
- After reviewing the records, including the various testimonies and discrepancies in evidence handling, the Supreme Court concluded that the deviations from the strict procedures mandated by Section 21 created reasonable doubt.
- The doubts centered on the authenticity and integrity of the seized drugs, making it impossible to rule beyond reasonable doubt that the evidence presented was indeed the same as what was seized in the operation.
Issues:
- Whether the accused-appellants, Pablito Pagaspas y Alcantara and Joey De Leon y Valeriano, are guilty beyond reasonable doubt of illegal sale of dangerous drugs under Section 5 in relation to Section 26 of Republic Act No. 9165.
- Whether Pablito Pagaspas is guilty beyond reasonable doubt of illegal possession of dangerous drugs under Section 11 of the same law, given the procedural lapses in the chain of custody and marking of evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)