Title
Supreme Court
People vs. Asislo y Matio
Case
G.R. No. 206224
Decision Date
Jan 18, 2016
Juan Asislo convicted for transporting 110kg of marijuana; chain of custody upheld despite lapses; life imprisonment and P1M fine affirmed.

Case Summary (A.M. No. RTJ-24-071)

Background of the Case

On July 21, 2009, the Regional Trial Court (RTC) found Asislo guilty of illegal sale of marijuana under Section 5 of Republic Act (R.A.) No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002. This conviction was later affirmed by the Court of Appeals on June 1, 2012. The RTC sentenced Asislo to life imprisonment and a fine of ₱5,000,000, while his co-accused, Jose Astudillo and Samuel Pal-iwen, were acquitted due to insufficient evidence.

Incident Timeline Leading to Arrest

The prosecution's case detailed a series of events beginning in April 2008, when the PDEA received intelligence regarding the distribution of marijuana in La Union, implicating Asislo. In April, a confidential informant named "Jojo" established communication with Asislo, leading to negotiations for the sale of 300 kilos of marijuana. Eventually, they agreed on a sale of 110 kilos, setting up a delivery for May 13, 2008.

buy-bust Operation

On the morning of May 13, 2008, PDEA operatives, having coordinated with the informant, set up a buy-bust operation where Asislo was to deliver the marijuana. Armed with information, the apprehending officers proceeded to the location where Asislo was expected to make the delivery. Upon arrival, Asislo and an accomplice delivered the marijuana in a vehicle, at which point the agents executed their arrest plan.

Arrest and Seizure of Evidence

Asislo was arrested shortly after opening a sack containing bricks of marijuana. The operation involved securing the evidence, which included five sacks of marijuana and a plastic bag containing additional marijuana, all promptly documented and sent for chemical analysis post-arrest. The collection and immediate submission of evidence were crucial for establishing the chain of custody.

Defense Strategy

The defense posited that the accused did not engage in the sale but merely facilitated transportation. They argued that there were lapses in the chain of custody and insufficient evidence to prove that Asislo was selling marijuana. Notably, the defense highlighted the lack of buy-bust money during the operation, contending that this undermined the prosecution's case of an illicit sale.

Legal Framework and Considerations

The core issues addressed by the courts involved the sufficiency of evidence to support a conviction for illegal sale or transportation of marijuana. Under Section 21 of R.A. No. 9165, important procedural safeguards for the handling of confiscated drugs were outlined, including immediate inventory and proper documentation to preserve the integrity of evidence. The prosecution was mandated to show an unbroken chain of custody from seizure through laboratory analysis and trial presentation.

Judicial Findings

Despite defense claims regarding procedural lapses, both the RTC and the Court of Appeals found that the essential integrity of the evidence was maintained. The courts concluded that the prosecution'

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