Case Summary (G.R. No. 224143)
Case Background
The legal proceedings arose from two separate Informations filed before the Regional Trial Court (RTC) in San Fernando City, La Union, charging Belmonte, Gumba, and Costales with violating Section 5, Article II of RA 9165 in Criminal Case No. 8979 (illegal sale of marijuana) and Gumba alone with violating Section 11, Article II of RA 9165 in Criminal Case No. 8997 (possession of marijuana). The alleged incidents occurred on November 23, 2010, with law enforcement led by Philippine Drug Enforcement Agency (PDEA) Agent Sharon Ominga conducting a buy-bust operation.
Incident Details
On the day of the offense, Agent Ominga received information about Gumba's marijuana sales, which led to the formation of a buy-bust team. The operation involved Ominga posing as a buyer, preparing marked money, and proceeding to a cemetery designated for the transaction. During the operation, Gumba was apprehended for selling a bundle of marijuana, while Belmonte was arrested when he confirmed the buyers' identity, and Costales escaped with the marked money. The subsequent inventory revealed additional quantities of marijuana, resulting in charges against the accused.
Defense and Testimonies
The defendants claimed innocence, asserting they were in the wrong place at the wrong time, with alibis presented by Belmonte, Gumba, and Costales. Belmonte described accompanying Gumba to the cemetery to visit a relative's tomb after briefly borrowing money. They contested the accusations by asserting they were unaware of any drug transactions. The defense focused on disproving the prosecution’s claims about the buy-bust operation's legitimacy.
RTC Ruling
In its November 23, 2011 ruling, the RTC found all defendants guilty, imposing life imprisonment and substantial fines for Belmonte and Costales for illegal sale of drugs, while Gumba received a lesser sentence due to his age. The RTC determined that the prosecution established proof of essential elements for drug sale, including the identity of the participants and the exchange of drugs for money, deeming the testimonies of law enforcement credible.
CA Ruling
Upon appeal, the Court of Appeals affirmed the RTC's ruling on June 30, 2015, supporting the prosecution's demonstrated chain of custody for the evidence against the defendants. The CA reasoned that the procedural shortcomings regarding the inventory signing did not compromise the integrity of the evidence, as the prosecution could trace the drugs from seizure to laboratory testing, maintaining their evidentiary value.
Supreme Court Decision
The Supreme Court upheld the lower courts' judgments, ruling that the prosecution had sufficiently met the burden of establishing the chain of custody of the seized drugs. The Court reiterated that while strict adh
...continue readingCase Syllabus (G.R. No. 224143)
Case Overview
- Court: Supreme Court of the Philippines
- Case Number: G.R. No. 224143
- Decision Date: June 28, 2017
- Petitioner: Kevin Belmonte y Goromeo
- Respondent: People of the Philippines
- Key Issues: Conviction for illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165.
Background of the Case
- The case originated from two separate Informations filed in the Regional Trial Court (RTC) of San Fernando City, La Union.
- Accused included Kevin Belmonte, Mark Anthony Gumba, and Billy Joe Costales for violating:
- Crim. Case No. 8979: Illegal sale of marijuana.
- Crim. Case No. 8997: Possession of marijuana against Gumba.
- The prosecution alleged that on November 23, 2010, the accused sold and possessed significant quantities of marijuana.
Facts of the Case
- Incident Date: November 23, 2010
- Location: San Gabriel, La Union, Philippines.
- A buy-bust operation was conducted by the Philippine Drug Enforcement Agency (PDEA) based on intelligence regarding Gumba selling marijuana.
- A PDEA agent posed as a buyer and coordinated with local police for a buy-bust team.
- During the operation, marked money was used, and marijuana was exchanged.
- After the transaction, Belmonte and Gumba were arrested, while Costales escaped with the marked money.
- A black bag containing additional marijuana was discovered after the arrest.
Prosecution's Evidence
- Testimony from PDEA Agent Sharon Ominga and the procedural execution of the buy-bust operation.
- Presentation of the seized marijuana in court, supported by laboratory examination confirming the substance as marijuana.
- Witnesses established the identity of the accused and the conditio