Case Digest (G.R. No. 250610) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Francis Valencia y Lorenzo and Ryan Antipuesto (G.R. No. 250610, July 10, 2023), the appellants were accused of selling 12.53 grams of methamphetamine hydrochloride (“shabu”) to a poseur buyer on January 16, 2016, at the exit gate of Dumaguete City Port. Officer Panggoy, acting as the poseur buyer, and Officer Basañez, as back-up, conducted a buy-bust operation coordinated with the Philippine Drug Enforcement Agency (PDEA). The seized heat-sealed sachet was marked “FLV/RA-BB-01-16-16,” inventoried, photographed at the police station due to port congestion, and submitted for laboratory examination. The forensic chemist testified that the white crystalline substance and Valencia’s urine sample tested positive for shabu. At trial, the Regional Trial Court convicted both appellants of violating Section 5 of Republic Act No. 9165, sentencing them to life imprisonment and a fine. The Court of Appeals affirmed, finding substantial compliance with the cha Case Digest (G.R. No. 250610) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- The People charged Francis Valencia y Lorenzo and Ryan Antipuesto with illegal sale of 12.53 g of methamphetamine hydrochloride (“shabu”) in Dumaguete City on January 16, 2016, under Section 5 of RA 9165.
- Upon arraignment, both pleaded not guilty; the case proceeded to trial before RTC Branch 30 of Negros Oriental.
- Prosecution’s Version of Buy-Bust Operation
- Surveillance by PNP officers Panggoy and Basa-Aez on Antipuesto, based on confidential informant tip; arrangement of buy-bust through informant.
- On January 16, the poseur buyer (Panggoy) approached Antipuesto and Valencia at the Dumaguete City Port exit, exchanged marked PHP 500 “bait money” for a heat-sealed sachet of shabu, then announced the arrest; Antipuesto escaped, Valencia was apprehended.
- Chain of Custody Handling
- Marking: Panggoy marked the plastic sachet “FLV/RA-BB-01-16-16,” placed it in a sealed brown envelope, and kept custody.
- Inventory & Photographs: Due to port traffic, inventory and photos were done later at the police station before DOJ, barangay, media witnesses.
- Laboratory Transfer: Panggoy submitted the envelope and Valencia’s urine sample to Police Officer III Caete, who resealed the envelope after noting and allowing alteration of the marking in the laboratory request from “2016” to “16.” Chemist Llena tested and confirmed shabu in both specimens.
- Defense Version
- Valencia’s alibi: Arrested in his boarding house by armed men, taken first to NBI then police station without seizure; witnesses Ragay and Rio saw no evidence confiscated at the scene.
- Antipuesto’s alibi: Drinking with a friend during the alleged transaction period and unaware of any buy-bust until subpoena.
- Trial and Appeals
- RTC convicted appellants of illegal sale of shabu, sentencing each to life imprisonment and P 500,000 fine, finding continuous chain of custody.
- CA affirmed conviction in toto, holding prior surveillance, coordination, and substantial compliance with Section 21 RA 9165 were established.
- SC granted review on whether guilt was proven beyond reasonable doubt, particularly on chain of custody compliance and integrity of corpus delicti.
Issues:
- Whether the buy-bust sale transaction was sufficiently proven.
- Whether the prosecution established the identity and integrity of the corpus delicti through an unbroken chain of custody under Section 21 of RA 9165.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)