Case Digest (G.R. No. 225736)
Facts:
People of the Philippines v. Alglen Reyes y Paulina, G.R. No. 225736, October 15, 2018, Supreme Court Second Division, Caguioa, J., writing for the Court.The complaint charged accused-appellant Alglen Reyes y Paulina with violating Section 5, Article II of R.A. No. 9165 for allegedly selling one (1) sachet of methamphetamine hydrochloride ("shabu") on July 5, 2011 in Barangay Malindong, Binmaley, Pangasinan. The Information alleged that Reyes "willfully and unlawfully sell Methamphetamine Hydrochloride or 'shabu' ... without any authority to sell the same," but did not specify the identity of the buyer, the exact quantity of the drug, or the consideration.
On the prosecution's version, a PNP buy‑bust team acting on an informant's tip conducted a sting the early dawn of July 5, 2011: PO3 Vaquilar acted as poseur-buyer using a P500 marked with his initials, the accused handed one small sachet in exchange for the marked bill, Vaquilar signalled arrest, frisked Reyes and recovered three additional sachets and other items, marked the sachets at the scene, and turned over the specimens to the PNP Crime Laboratory the same day where a forensic chemist tested and found them positive for methamphetamine hydrochloride. The arresting officers testified that they recorded the operation and prepared a confiscation receipt.
Reyes' defense presented a different narrative: he claimed he was at a lighted gas station to refuel at night after being sent to buy medicine, was abruptly handcuffed and taken by four men in civilian clothes wearing helmets, was not shown any seized items, and that his family had given him P1,000 for the errand. A family witness corroborated that Reyes left with P1,000 to buy medicine and was later told of the arrest.
The Regional Trial Court (RTC), Branch 39, Lingayen, Pangasinan, after trial convicted Reyes in a November 29, 2012 decision, finding the elements of illegal sale proven, tracing the chain of custody, and giving credence to police testimony; it sentenced Reyes to life imprisonment and fined him P500,000, ordered the four sachets confiscated and other items returned. Reyes appealed to the Court of Appeals (CA).
In a September 9, 2015 decision in CA-G.R. CR-HC No. 05890, the CA affirmed the RTC, finding (1) the elements of sale proven and (2) that although Section 21,...(Pro-only)
Issues:
- Was the Information sufficient to inform Reyes of the offense charged in violation of the requirements of Rule 110, Sections 8 and 9 of the Rules of Court?
- Did the prosecution prove Reyes' guilt beyond reasonable doubt, in particular by preserving the chain of custody in compliance with Section 21, Article II of the IRR of R.A. No. 9165 (or ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)