Case Digest (G.R. No. 236455)
Facts:
People of the Philippines v. Haron Ramos y Rominimbang, G.R. No. 236455, February 19, 2020, Supreme Court First Division, Peralta, C.J., writing for the Court.The accused-appellant Haron Ramos y Rominimbang was charged by Information dated March 21, 2012 with violation of Section 5, Article II of R.A. No. 9165 (illegal sale of dangerous drugs) for allegedly selling a heat-sealed plastic sachet containing 47.3752 grams of shabu to a poseur-buyer on March 15, 2012 in Manila. Ramos pleaded not guilty at arraignment and was detained at the Manila City Jail during trial.
At trial, the prosecution presented PDEA operatives — IO1 Lawrence Anthony Dalignon (poseur-buyer) and IO1 Angelito Villaspin (arresting officer) — and relied on stipulated testimonies of SOIII Romano Alfonso and media representative Jimmy Mendoza. The prosecution described a buy-bust: after a briefing at the PDEA Regional Office and coordination with the Manila Police District, the poseur-buyer purportedly consummated the sale in front of SM Manila; Dalignon signaled arrest by removing his cap; Ramos was arrested; the buy-bust money was recovered; the operatives brought Ramos and the seized items to the PDEA RO-NCR where the seized items were inventoried and photographed in the presence of a barangay official and a media representative; PDEA chemist Ronald V. Bobis later tested the seized substance positive for methamphetamine hydrochloride.
The defense presented Ramos and his wife, Florence, who testified that Ramos was accosted and forcibly taken by several men in SM Manila, beaten inside a vehicle, brought to the PDEA Office where demands for ransom were made, photographed with planted items, and told to deny that he had been beaten; Florence said she was briefly detained and released. The defense contested the identity and integrity of the seized sachet and asserted lack of probable cause for arrest.
The Regional Trial Court, Branch 13, City of Manila, in an August 19, 2016 Decision convicted Ramos of illegal sale under Section 5, R.A. No. 9165 and sentenced him to life imprisonment and a fine of P500,000. The Court of Appeals in CA-G.R. CR-HC No. 08593 affirmed the RTC in an August 17, 2017 Decision, finding that the prosecution proved all elements of the sale, that Ramos was caught in flagrante and that non-strict compliance with Section 21 of the IRR of R.A. No. 9165 was justified and did not break the chain of custody.
The People and Ramos did not file supplemental brief...(Pro-only)
Issues:
- Did the prosecution establish the chain of custody and justify non-compliance with Section 21 of R.A. No. 9165 and its IRR so as to preserve the integrity and evidentiary value of the seized drug exhibit?
- Did the prosecution prove beyond reasonable doubt the elements of illegal sale under Section 5, Article II of R.A. No. 9165 (identity of buyer/seller, object and considera...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)