Case Digest (G.R. No. 203834) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 227706, decided on June 14, 2023 under the 1987 Constitution, the People of the Philippines charged Allan Almayda y Selfides and Homero Quiogue y Adornado with selling methamphetamine hydrochloride (“shabu”) in Legazpi City on April 19, 2012. A confidential informant coordinated with the Philippine Drug Enforcement Agency (PDEA) for a buy-bust operation in which Agent Daniel Tan posed as the buyer. Almayda delivered two heat-sealed sachets containing a total of 0.390 gram of shabu in exchange for ₱4,500, passing the marked money to Quiogue. Upon signal, PDEA agents arrested both, recovered the money, marked the sachets at the scene, and photographed the items. The items were inventoried and photographed at the PDEA Regional Office in the presence of barangay officials, a DOJ representative, media, and the accused; subsequent laboratory analysis confirmed the substance as methamphetamine hydrochloride. At trial, the court found the agents’ testimony credible, upheld t Case Digest (G.R. No. 203834) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Information, Arraignment, and Trial
- On April 20, 2012, the Department of Justice filed an Information charging Allan Almayda y Selfides and Homero Quiogue y Adornado with violation of Section 5, Article II, in relation to Section 26(b) of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), for allegedly selling two heat-sealed sachets of methamphetamine hydrochloride (“shabu”) weighing 0.318 g and 0.072 g for ₱4,500.00.
- Upon arraignment, the accused-appellants pleaded not guilty, and trial commenced.
- Prosecution’s Version
- In March 2012, a confidential informant reported to PDEA Regional Office V that Quiogue and an alias “Kalaw” (later identified as Almayda) were peddling shabu in Legazpi City. A buy-bust team was organized: Agent Mari-Niaa Z. Belo (team leader), Agent Daniel Tan (poseur-buyer), Agent Enrique Lucero (arresting officer), and other agents.
- On April 18, 2012, a meeting was arranged between the informant and the accused. Only Almayda attended, stating a minimum price of ₱4,500.00. They agreed to rendezvous the following day at 7th Inn’s Bulaluhan Resto Bar.
- On April 19, the buy-bust team, posing as buyers, proceeded to 7th Inn. Almayda handed two heat-sealed sachets containing white crystalline substance to Agent Tan, who then gave him the marked ₱4,500.00. Almayda passed the money to Quiogue. Agent Tan signaled consummation by removing his cap.
- Upon arrival of the rest of the team, Agent Lucero recovered the marked money from Quiogue. Agent Tan immediately inscribed “DMT A 4-19-12” and “DMT B 4-19-12” on the sachets. Photographs of the accused and seized items were taken at the scene.
- The team brought the items to the PDEA Regional Office, where an inventory and further photographs were conducted in the presence of barangay officials, a DOJ representative, media, and the accused. The items were forwarded to the PNP Crime Laboratory, and Forensic Chemist Wilfredo Idian Pabustan, Jr. confirmed the presence of methamphetamine hydrochloride per Chemistry Report No. D-53-2012 dated April 19, 2012.
- Defense Version
- The accused-appellants testified that Almayda, having attended a court hearing earlier that day, merely met Quiogue at 7th Inn when PDEA agents arrived, handcuffed them, confiscated their cash and phones, and escorted them to the PDEA office for questioning.
- They denied any sale of illegal drugs.
- Trial Court Judgment (August 23, 2013)
- The Regional Trial Court found the accused guilty beyond reasonable doubt of selling shabu under Section 5, first paragraph, in relation to Section 26(b) of RA 9165.
- The accused were sentenced to life imprisonment and a fine of ₱1,000,000.00 each. The court credited the testimony of PDEA agents and upheld the chain of custody.
- Court of Appeals Decision (August 11, 2015)
- The Court of Appeals affirmed the conviction, ruling that the prosecution had satisfactorily proven all elements of the offense and preserved the chain of custody.
- Supreme Court First Resolution (November 11, 2021)
- The Supreme Court (Special First Division) denied the accused-appellants’ motion for reconsideration, affirming the Court of Appeals and trial court findings, particularly on identification and chain of custody.
- Motion for Reconsideration Before the Supreme Court (April 7, 2022)
- The accused-appellants argued that the physical inventory and photograph-taking of the seized shabu were not conducted at the place of arrest, violating Section 21 of RA 9165, and that no explanation was offered for the deviation.
- Supreme Court’s Final Ruling (June 14, 2023)
- The Supreme Court granted the motion for reconsideration, reversed the November 11, 2021 Resolution, acquitted the accused-appellants as a matter of right, and ordered their immediate release.
- The Court held that failure to justify the off-site inventory at the PDEA Regional Office constituted a break in the first link of the chain of custody, irreparably compromising the integrity and evidentiary value of the seized items.
Issues:
- Whether the chain of custody was broken by conducting the physical inventory and photograph-taking of the seized drugs at the PDEA Regional Office instead of at the place of arrest.
- Whether the absence of any justification for this procedural deviation under Section 21 of RA 9165 mandates acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)