Case Summary (G.R. No. 205787)
Applicable Law
The applicable law in this case is Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, which defines offenses related to the sale, possession, and use of dangerous drugs, alongside the procedures necessary for evidence handling and chain of custody.
Prosecution’s Case
The prosecution argued that on September 21, 2005, during a police-led buy-bust operation, the accused facilitated the sale, possession, and use of methamphetamine hydrochloride (shabu). Evidence included the testimonies of officers involved in the operation, the confiscation of illegal substances and paraphernalia at the scene, and the results from chemical examinations conducted on the seized drugs.
Defense’s Claims
The defense contended that the arrests and subsequent evidence collection were conducted improperly. The accused maintained they were at a friend's house to borrow money at the time of their arrest. They alleged that the police improperly planted drugs and paraphernalia as evidence during a supposed raid, claiming no reasonable links could be established between the items presented in court and those allegedly seized during the operation.
Court of First Instance Ruling
The Regional Trial Court found both accused guilty beyond reasonable doubt. Arposeple received a life sentence along with heavy fines for selling drugs, while both faced sentences related to possession of the drugs and paraphernalia that allegedly linked them to drug-related activities. Sulogaol was acquitted as evidence against him was found insufficient.
Court of Appeals Ruling
The Court of Appeals upheld the convictions, asserting that the prosecution's evidence sufficiently established the elements of the crime, though it modified the fine in one of the counts. The CA commented on the credibility of witnesses and their testimonies, emphasizing their observed demeanor during trial and the substantial compliance with chain of custody requirements despite some procedural shortcomings.
Review by the Supreme Court
In reviewing the appeal, the Supreme Court noted the constitutional presumption of innocence and required the prosecution to prove guilt beyond reasonable doubt. The Court criticized the prosecution for failing to establish an unbroken chain of custody for the seized drugs, which it identified as critical evidence. It highlighted significant procedural lapses regarding the marking, inventory, and documentation of evidence, which raised reasonable doubt about the integrity of the confiscated items.
Findings on Chain of Custody
The Supreme Court articulated that the integrity of the chain of custody must be maintained to ensure the admissibility of evidence in drug-related cases. The Court identified a critical failure in how the drugs were handled after being seiz
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Background
- The case revolves around the appeal of Pablo Arposeple y Sanchez (Arposeple) and Jhunrel Sulogaol y Datu (Sulogaol) against a decision from the Court of Appeals (CA) affirming their convictions for drug-related offenses.
- The appeal was filed following the 3 October 2011 decision of the CA, which modified the fine imposed by the Regional Trial Court (RTC) on Arposeple in Criminal Case No. 12853 while affirming the other convictions.
Charges
- The accused faced three criminal cases under the Comprehensive Dangerous Drugs Act of 2002 (R.A. No. 9165):
- Criminal Case No. 12852: Selling methamphetamine hydrochloride (shabu).
- Criminal Case No. 12853: Possession of shabu leftovers.
- Criminal Case No. 12854: Possession of paraphernalia for using drugs.
Facts of the Case
- On 21 September 2005, a buy-bust operation was conducted by the police in Tagbilaran City, targeting the accused.
- During the operation, the police arrested both appellants after they allegedly sold shabu to an undercover officer.
- Evidence seized during the arrest included various items related to the sale and use of shabu.
Prosecution's Version
- The prosecution presented multiple witnesses, including police officers and a barangay official, to establish the circumstances of the buy-bust operation.
- Testimonies indicated that the accused were caught in