Title
People vs. Reyes
Case
G.R. No. 199271
Decision Date
Oct 19, 2016
Jehar Reyes acquitted due to broken chain of custody and procedural lapses in a buy-bust operation for illegal shabu sale under R.A. No. 9165.
A

Case Digest (G.R. No. 199271)

Facts:

  • Charge and operative facts
    • On November 27, 2002, at around 2:00 PM in Sitio Cayam, Brgy. Ward I, Tiber, Minglanilla, Cebu, PO2 Jesus Rudson Villahermosa and PO1 Januario Miro, acting as poseur-buyers, approached accused Jehar Reyes’s residence for a buy-bust operation.
    • Reyes allegedly sold one plastic pack of white crystalline substance (later marked “JR-B”) to the poseur-buyers for ₱1,000.00; upon arrest and frisk, two additional packs (“JR-1” and “JR-2”) were recovered from his person. The total weight of the three packets was 1.44 g.
  • Prosecution and defense versions
    • Prosecution witnesses (Villahermosa, Miro, Insp. Arnel Banzon, P03 Marlon Lumayag, Jude Daniel Mendoza) recounted surveillance, the buy-bust transaction, immediate arrest, marking of the seized packs, submission for laboratory testing (Chemistry Report No. D-2390-2002), and positive results for methamphetamine hydrochloride.
    • Defense witnesses (the accused and neighbor Cesar Canada) denied any sale: Canada testified that police illegally entered without a warrant while Reyes was asleep, found no money or shabu during the search, and forcibly brought Reyes away; no buy-bust transaction occurred.
  • Lower court decisions
    • RTC (Branch 10, Cebu City) on March 9, 2007 convicted Reyes of illegal sale under Sec. 5, Art. II, RA 9165, sentencing him to life imprisonment and ₱500,000 fine; ordered confiscation and destruction of the shabu packets.
    • CA on June 13, 2011 (CA-G.R. CEB CR-H.C. No. 00792) affirmed conviction, holding that (a) the sale transpired, (b) the corpus delicti was properly marked and preserved, and (c) the chain of custody was unbroken despite minor procedural deviations.

Issues:

  • Whether the Court of Appeals erred in affirming Reyes’s conviction for illegal sale of dangerous drugs under Sec. 5, Art. II of RA 9165.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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