Case Digest (G.R. No. 268839)
Facts:
People of the Philippines v. Aldrin Palacios y Fejedero alias "Anding" and Noel Gaitan, Jr. y Bermundo, G.R. No. 268839, August 20, 2025, Supreme Court Third Division, Inting, J., writing for the Court.The accused-appellants, Aldrin Palacios y Fejedero (Palacios) and Noel Gaitan, Jr. y Bermundo (Gaitan), were charged in three separate informations with Illegal Sale (Section 5, Republic Act No. 9165) and Illegal Possession (Section 11, RA 9165) of methamphetamine hydrochloride (“shabu”). Upon arraignment they pleaded not guilty and trial followed in Branch 84, Regional Trial Court (RTC), Batangas City.
The prosecution’s version was that on January 4, 2021 the San Jose Municipal Police Station conducted a buy-bust operation after a confidential informant reported Palacios as a seller. PSSg Ronald Punzalan acted as the poseur-buyer using one genuine marked ₱1,000 bill and several fake ₱1,000 bills; a transaction occurred at about 2:30 a.m. when Palacios received the marked money and, with Gaitan’s assistance, handed a sachet of suspected shabu to PSSg Punzalan. Apprehending officers recovered marked money and multiple heat-sealed sachets from the suspects; the officers marked and inventoried the items in the presence of the accused and two insulating witnesses (a media representative and a barangay councilor), photographed the process, turned the items over to the investigator, and eventually delivered them to the provincial crime laboratory where forensic examinations (Chemistry Reports BD-001-2021 and BD-002-2021) tested positive for methamphetamine hydrochloride.
The defense denied the charges, claiming police instigation/entrapment, alleged blindfolding and illegal detention, and that police later laid out and photographed drugs before formal custody. They also narrated Palacios had gone to deliver a package at the behest of a third party and did not know its contents.
The RTC, in a Consolidated Decision dated May 14, 2021, found the prosecution proved the elements of Illegal Sale and Illegal Possession beyond reasonable doubt, ruled the buy-bust valid, and that inventory/marking and chain of custody were properly complied with; it convicted Palacios and Gaitan and sentenced them (specified terms and fines), ordered evidentiary items transmitted to PDEA, and forfeited the marked money to the Government. The accused appealed to the Court of Appeals (CA-G.R. CR-HC No. 15614). The Court of Appeals, in a Decision dated December 14, 2022 (Second Division, penned by Associate Justice Fernanda Lampas Peralta, with Rafael Ant...(Subscriber-Only)
Issues:
- Procedural: Did the prosecution establish the integrity of the seized drugs through an unbroken chain of custody such that any claimed deviations (distance of witnesses, delay in turnover) do not vitiate admissibility?
- Substantive: Was the guilt of accused-appellants for Illegal Sale (Section 5) and Illegal Possession (Section 11) of dangerous drugs pr...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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