Case Summary (G.R. No. 228958)
Facts and Antecedent Proceedings
Eutiquio Baer was charged in two Criminal Cases under Republic Act No. 9165—the Comprehensive Dangerous Drugs Act of 2002—specifically for illegal sale and illegal possession of dangerous drugs. The charges arose from an incident on December 3, 2002, in Bato, Leyte, where Baer was found in possession of several bags of methamphetamine hydrochloride, commonly known as "shabu." During his arraignment in May 2003, Baer pleaded not guilty. The RTC trial culminated in a conviction for illegal possession, leading to a life sentence, while he was acquitted of illegal sale due to insufficient evidence.
Evidence for the Prosecution
The prosecution's evidence indicated that authorities conducted a search warrant execution at Baer's rented stall, where seven sachets and 142 decks of shabu were discovered inside a locked steel box, later opened with a key obtained from a third party. The search was witnessed by barangay officials, and the seized items were forwarded to the police laboratory, which confirmed their identity as illegal drugs.
Evidence for the Defense
Baer denied ownership of the steel box and contended that he had merely allowed a friend to leave it in his stall. He claimed he was not in the stall during the search and was unaware of the box's contents. Witnesses corroborated his testimony, stating that no formal search warrant was shown to Baer during the execution of the search.
Ruling of the RTC
On January 12, 2009, the RTC convicted Baer for illegal possession of drugs while acquitting him regarding the sale of drugs, leading to a life sentence and substantial fines.
Ruling of the CA
The CA upheld the RTC's decision, affirming that Baer had constructive possession of the illegal drugs as they were found in his rented stall. The CA determined that the integrity of the seized items was preserved.
Issue
The core issue for resolution is whether the RTC and CA erred in convicting Baer for violating Section 11, Article II of RA 9165, specifically in light of the prosecution's failure to meet the required burden of proof.
The Court's Ruling
The Supreme Court acquitted Baer, highlighting that the prosecution failed to prove the elements of illegal possession beyond a reasonable doubt. It emphasized that constructive possession could not be established, as Baer had no access to the steel box's key and clearly stated that the box belonged to another individual, Notarte.
Chain of Custody and Procedural Violations
The Court found substantial procedural violations related to the handling of seized evidence. The prosecution fail
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Case Overview
- The case involves an ordinary appeal filed by accused-appellant Eutiquio Baer, also known as "Tikyo," contesting the Decision rendered by the Court of Appeals (CA) dated August 31, 2016.
- The CA affirmed the January 12, 2009 Decision of the Regional Trial Court (RTC) of Hilongos, Leyte, which found Baer guilty beyond reasonable doubt of violating Section 11, Article II of Republic Act No. 9165, known as "The Comprehensive Dangerous Drugs Act of 2002," while acquitting him of the charge of illegal sale of dangerous drugs.
- The case number for the RTC ruling is Criminal Case No. H-1176, and the CA case number is CA-G.R. CEB-CR. HC No. 01343.
Facts and Antecedent Proceedings
- Baer was charged in two separate Informations for violations related to illegal sale and possession of dangerous drugs under RA 9165.
- The charges stemmed from events that occurred on December 3, 2002, in Bato, Leyte, where Baer was accused of possessing and selling methamphetamine hydrochloride (shabu).
- Baer entered a not guilty plea during his arraignment on May 29, 2003, and remained in detention during the proceedings.
Evidence for the Prosecution
- The prosecution's evidence included testimonies from police officers who executed a search warrant at Baer's rented stall, where they allegedly found several plastic sachets of shabu.
- Baer reportedly admitted the presence of prohibited drugs and led the officers to a locked steel box, which contained the seized drugs.
- The drugs were later examined by a