Title
Supreme Court
People vs. Anthony David y Matawaran
Case
G.R. No. 260990
Decision Date
Jun 21, 2023
Appeal on illegal sale and possession of dangerous drugs due to procedural lapses in chain of custody and inventory leading to acquittal for failure to prove guilt beyond reasonable doubt.

Case Digest (G.R. No. 260990)
Expanded Legal Reasoning Model

Facts:

  • Background
    • Anthony David y Matawaran @ "Anto" (accused-appellant) was charged with two separate offenses under Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002):
      • Illegal Sale of Dangerous Drugs (Criminal Case No. 15095)
      • Illegal Possession of Dangerous Drugs (Criminal Case No. 15096)
    • Both charges arose from alleged acts committed on August 16, 2015, in Samal, Bataan.
    • The accused pleaded not guilty.
  • Details of the Alleged Crimes
    • Illegal Sale Case:
      • Accused-appellant was alleged to have sold a heat-sealed sachet containing 0.0504 gram of methamphetamine hydrochloride ("shabu") to a poseur-buyer.
    • Illegal Possession Case:
      • Accused-appellant was alleged to have been found in possession of another heat-sealed sachet containing 0.0648 gram of the same substance.
  • Police Operation and Arrest
    • Police officers received information from a confidential informant about accused-appellant's involvement in illegal drug sales.
    • A buy-bust team was formed including PO1 Joey Santos as poseur-buyer and SPO1 Rommel Buduan as backup.
    • The buy-bust operation was conducted with money marked "JCS" for the purchase.
    • PO1 Santos purchased the alleged drug, placed it in his right pocket, then arrested accused-appellant after introducing himself as a policeman.
    • A subsequent frisk recovered another sachet of "shabu" and the marked buy-bust money from accused-appellant.
    • Seized items were marked as "JCS-1" (sale item) and "JCS-2" (possession item) after the arrest.
    • The items were inventoried and photographed at the police station in the presence of witnesses including DOJ representatives, media, and a barangay official.
    • The specimens tested positive for methamphetamine hydrochloride at the crime laboratory.
  • Defense Testimony
    • Accused-appellant denied the allegations, claiming he was arrested while driving his tricycle without any drug transaction.
    • He said the police officers handcuffed and frisked him without any apparent reason.
    • His father confirmed he visited the police station after receiving notice of his son's arrest.
  • Trial Court Decision
    • RTC convicted accused-appellant of both charges beyond reasonable doubt.
    • The court credited the prosecution’s witnesses, particularly the police officers’ testimony.
    • Sentences:
      • Life imprisonment without parole and a fine of PHP 500,000 for Illegal Sale.
      • 15 years and 1 day to 20 years imprisonment without parole and a fine of PHP 300,000 for Illegal Possession.
  • Appeal
    • Accused-appellant appealed to the Court of Appeals (CA).
    • CA affirmed the RTC decision in toto.
  • Supreme Court Review
    • The main issue is whether the prosecution proved the accused's guilt beyond reasonable doubt.

Issues:

  • Whether accused-appellant is guilty beyond reasonable doubt of Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II, RA 9165.
  • Whether the prosecution complied with the strict requirements on chain of custody of the seized drug evidence as mandated by Section 21, RA 9165, as amended by RA 10640.
  • Whether there was compliance with the procedural requirements on the inventory and photographing of seized drugs at the place of seizure or at the nearest police station with justifiable grounds.
  • Whether the integrity of the seized drugs was preserved to prove the identity of the corpus delicti throughout the proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.