Case Digest (G.R. No. 233535)
Facts:
People of the Philippines v. William Rodriguez y Bantoto, G.R. No. 233535, July 01, 2019, Supreme Court First Division, Del Castillo, J., writing for the Court. The accused-appellant is William Rodriguez y Bantoto; the People of the Philippines prosecuted him for violations of Sections 5 and 11(3), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).On July 26–27, 2013, members of the Manila Police District District Anti-Illegal Drugs (DAID), coordinated with a confidential informant (CI), the investigative program crew of Imbestigador ng Bayan, and Philippine Drug Enforcement Agency (PDEA) personnel, mounted a buy-bust at a pension house on M.G. Del Pilar Street. PO3 Fred Martinez acted as the poseur-buyer. The prosecution's version was that the CI and an alias “Dang” introduced PO3 Martinez to accused-appellant, who accepted marked money and handed a marked heat-sealed sachet labeled “DAID.” After the buy-bust signal, police arrested accused-appellant; they recovered the marked buy-bust money and five unsealed sachets on the table labeled “FSM,” “FSM-1,” “FSM-2,” “FSM-3,” and “FSM-4.” Barangay tanods signed the inventory because the Imbestigador crew allegedly refused to sign; photographs were taken; samples tested positive for methamphetamine hydrochloride.
Accused-appellant denied guilt, claiming he was surprised by armed intruders, handcuffed, and that he did not know the origin of the drugs seen on the table. At trial the Regional Trial Court (RTC), Branch 2, Manila, after trial by evidence, found accused-appellant guilty beyond reasonable doubt of illegal sale under Section 5, Article II of RA 9165 (Crim. Case No. 13-298732) and sentenced him to life imprisonment and P500,000 fine, but acquitted him of illegal possession under Section 11, Article II (Crim. Case No. 13-298733) due to the failure to preserve identity/integrity of the five unsealed sachets. The Court of Appeals (CA), in CA-G.R. CR-HC No. 08151, affirmed the RTC decision, finding the chain of custody intact and deeming absence of a DOJ representative nonfatal where no break was shown.
Accused-appellant appealed to the Supreme Court. The Supreme Court First Division, through the Decision penned by Justice Del Castillo, granted the appeal, reversed and set aside the ...(Pro-only)
Issues:
- Did the prosecution comply with Section 21, Article II of RA 9165’s requirement that the physical inventory and photographing of seized items be witnessed by insulating witnesses (an elected public official, a representative from the media, and a representative from the DOJ) who sign and receive copies of the inventory?
- If there was noncompliance with Section 21, did the prosecution allege and prove justifiable grounds for that absence and show that earnest efforts were exerted to secure the required witnesses?
- In view of the above, did the prosecution prove the accused-appellant’s guilt beyond reasonable dou...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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