Case Digest (G.R. No. 216014)
Facts:
People of the Philippines v. Edwin Sanchez y Salvo a.k.a. "Dada", G.R. No. 216014, March 14, 2018, Supreme Court Third Division, Leonen, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Edwin Sanchez y Salvo.Two Informations were filed in the Regional Trial Court (Branch 39, Calapan City) charging Sanchez with (1) sale of methamphetamine hydrochloride ("shabu") weighing 0.215 grams (violating Section 5 of Republic Act No. 9165) and (2) possession of another sachet containing 0.211 grams of shabu (violating Section 11 of RA 9165). At arraignment Sanchez pleaded not guilty and trial followed.
The prosecution presented testimony from buy-bust team members: IO1 Kathleen Diocampo (poseur-buyer), IO1 Mario Rinopa (arresting officer), P/S Insp. Rhea Fe dela Cruz Alviar (laboratory examiner), Punong Barangay Cresente Mendoza, Jr., and DOJ representative Pedro Magnaye. The narrative was that PDEA Regional Office IV-B organized a buy-bust on August 10, 2008; Diocampo posed as buyer "Kat-Kat" with two marked P500 bills; Sanchez sold a sachet for marked money; the team then arrested him, recovered the marked money and an additional sachet, marked the seized items, inventoried them in the presence of the barangay captain and DOJ rep, and Diocampo personally delivered the items to the crime laboratory where P/S Insp. Alviar confirmed they were methamphetamine hydrochloride.
Sanchez testified in his own defense, denying guilt and alleging a "frame up": he said he was visiting from Laguna, was drinking with five men, was taken to the PDEA office where he completed forms and later was declared under arrest after agents produced money and sachets; he recounted prolonged detention and asserted the buy-bust was fabricated. He did not present the persons he was allegedly drinking with as witnesses.
On November 8, 2011, the RTC convicted Sanchez in both cases, finding the prosecution proved the elements of sale and of possession and that the chain of custody was unbroken; it sentenced him to life imprisonment and a P500,000 fine for the sale count, and an indeterminate term (12 years and 1 day to 15 years and 1 day) and P300,000 fine for possession. The trial court relied on established elements articulated in precedents such as People v. Cruz and People v. Castro.
Sanchez appealed to the Court of Appeals, which in a July 14, 2014 Decision (Special Seventeenth Division) affirmed the RTC convictions, holding that the minor discrepancy between witnesses about where the seized items were marked did not impair the credibility of the police witnesses a...(Pro-only)
Issues:
- Did the prosecution establish an unbroken chain of custody of the seized items despite inconsistent testimony on where the items were marked?
- Did the prosecution prove beyond reasonable doubt the elements of the crimes of sale (Sec. 5, RA 9165) and possession (Sec. 11, RA 9165...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)