G.R. No. 250908 - People vs. Quinones y Loveria

On June 14, 2015, at around 3:40 in the afternoon, Jail Officer Niel A. Romana conducted a routine roll call at the second floor of the Camarines Norte Provincial Jail.
During the roll call, Officer Romana accosted inmate Rogelio B. Caparas—a minor and trustee-inmate—when he was en route to inmate Frederick Cua’s cell.

Upon questioning, Caparas was bodily searched by Officer Romana.
A small piece of paper sealed with black electrical tape was found in Caparas’ pocket; upon opening, it revealed a handwritten note.
Alongside the note, a small plastic sachet containing 0.0944 gram of a white crystalline substance and a rolled aluminum foil were also discovered.
The seized items were inventoried and photographed in the presence of Philippine Drug Enforcement Agency Agent Enrico Barba, Barangay Officials, and Media Representative Ricky Pera.
A subsequent qualitative examination at the crime laboratory confirmed that the substance was methamphetamine hydrochloride (commonly known as shabu).

Provincial Warden Reynaldo Pajarillo corroborated Officer Romana’s account on key aspects of the incident.
Inmate Caparas testified that the note and plastic sachet were given to him by the accused-appellant, Ariel QuiAones y Loveria.
Caparas claimed that he was instructed by the accused-appellant to deliver the items to inmate Frederick Cua, who was identified as the intended recipient or buyer.

Accused-appellant denied the charges, asserting that he was in his cell on the first floor during the time of the incident.
He stated that he was summoned by Caparas to report to the Office of the Provincial Warden, where he observed Caparas, Officer Romana, and three other individuals, and was informed of the charges against him.
He denied any involvement in the transmission or handling of the seized items and refused to sign the inventory report, stating that he was not their owner.
He maintained that he did not leave his cell from 3:30 in the afternoon until 9:00 in the evening.

The Regional Trial Court (RTC) of Daet, Camarines Norte, Branch 38, in its Judgment dated September 4, 2017, found the accused-appellant guilty beyond reasonable doubt of Attempted Illegal Sale of Dangerous Drugs.
The RTC sentenced accused-appellant to life imprisonment and imposed a fine of P500,000.00.
The Court of Appeals (CA) later affirmed the RTC’s decision in its Decision dated November 29, 2018, relying mainly on Caparas’ testimony and the integrity of the chain of custody of the seized items.
Based on these proceedings, the accused-appellant filed an ordinary appeal to challenge the conviction.

Whether or not the accused-appellant is guilty beyond reasonable doubt of the crime of Attempted Illegal Sale of Dangerous Drugs.

Whether the prosecution met the burden of proving beyond reasonable doubt the identification of the accused-appellant as the seller/source of the illegal drug.
The sufficiency and credibility of Caparas’ testimony, particularly given that he was found in possession of the seized shabu and had a potential interest in diverting criminal liability.
Whether the lack of independent corroborative evidence—especially regarding the identities of both buyer and seller—undermines the integrity of the prosecution’s case.

The role and reliability of the chain of custody and the forensic evidence in establishing the origin and intended delivery of the seized items.
The effectiveness of the corroborative testimonies (from Officer Romana and Warden Pajarillo) in substantiating Caparas’ claim against the accused-appellant.