Case Digest (G.R. No. 171053)
Facts:
This is People of the Philippines v. Ma. Del Pilar Rosario C. Casa, G.R. No. 254208, August 16, 2022, the Supreme Court En Banc, Gesmundo, C.J., writing for the Court. The accused-appellant is Ma. Del Pilar Rosario C. Casa (a.k.a. “Marfy Calumpang,” “Madam,” “Mah-mah”), who was charged in two informations with (1) illegal sale of 0.13 gram of methamphetamine hydrochloride (shabu) (Crim. Case No. 2015‑23066) in violation of Section 5, Article II of R.A. No. 9165, and (2) illegal possession of an aggregate 10.99 grams of shabu in 11 sachets (Crim. Case No. 2015‑23067) in violation of Section 11, Article II of R.A. No. 9165, as amended by R.A. No. 10640. She pleaded not guilty at arraignment on July 31, 2015 and was tried on the merits.The prosecution’s theory: a buy‑bust operation on July 21, 2015 in Cadawinonan Housing Project, Dumaguete City. Police Officer I Darelle Jed Delbo served as the poseur‑buyer; he testified that he gave P500 marked money to accused‑appellant and received one heat‑sealed sachet (marked “MC‑BB 7/21/15”). Backup officers allegedly recovered a plastic container holding 11 marked sachets (“MC‑P1 7/21/15” to “MC‑P11 7/21/15”) and the items were inventoried at the SOG office in the presence of insulating witnesses. Forensic examination (Chemistry Report No. DT‑205‑15) and a urine test returned positive for methamphetamine. The prosecution presented seven witnesses (including PO1 Delbo, PO1 Olasiman, SPO4 Germodo, PDEA officers and a DOJ representative).
The defense: accused‑appellant denied wrongdoing, claimed she was dragged out by two men (later identified as PO1 Delbo and SPO4 Germodo), was forced into a white pickup, saw the drugs only at the SOG office, and suggested police framed her because of her estranged husband’s alleged drug dealing.
The Regional Trial Court (RTC), Branch 30, Dumaguete City, rendered a Joint Judgment on March 28, 2017 finding accused guilty of both counts and imposing life imprisonment and fines; the RTC credited the prosecution witnesses and held the buy‑bust and chain of custody procedures were properly followed. The Court of Appeals (CA), Cebu City, affirmed in a November 29, 2018 Decision in CA‑G.R. CR‑HC No. 02574....(Subscriber-Only)
Issues:
- Did the trial court err in crediting the uncorroborated testimony of the poseur‑buyer (PO1 Delbo)?
- Did the prosecution prove compliance with Section 21(1) of R.A. No. 9165, as amended by R.A. No. 10640 (the chain of custody requirements)?
- Was the prosecution’s evidence sufficient to prove beyond reasonable doubt the elements of illegal sale and illeg...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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