Case Summary (G.R. No. 240541)
Facts of the Case
This case originated from an Information filed before the Regional Trial Court (RTC), accusing Barrion of Illegal Sale of Dangerous Drugs as defined under Section 5, Article II of Republic Act No. 9165, known as the "Comprehensive Dangerous Drugs Act of 2002." The prosecution's case presented that on August 10, 2011, police officers conducted a buy-bust operation leading to Barrion's apprehension, during which he was found with a plastic sachet containing methamphetamine hydrochloride or shabu.
Prosecution's Evidence
During the operation, PO2 Dan Gonzales marked the seized substance immediately after Barrion's arrest. This item was inventoried in the presence of a Department of Justice representative, Rodel Limbo, and barangay councilor Teresita N. Reyes. Subsequent laboratory tests confirmed the substance was shabu weighing 0.04 grams. The police maintained that their actions followed legal protocols regarding the handling of drugs.
Accused's Defense
Barrion disputed the allegations, asserting that he was already in custody when the alleged transaction occurred. He claimed police officers apprehended him later that evening after allegedly attempting to extort information about drug sources. His defense centered on alibi and a denial of involvement in drug dealing.
Trial Court's Decision
The RTC ruled on April 29, 2016, finding Barrion guilty. The court determined that the prosecution had satisfactorily proved all elements of the crime including the identity and integrity of the corpus delicti, thereby upholding the presumption of regularity in police conduct.
Court of Appeals Decision
Barrion appealed to the Court of Appeals, which affirmed the RTC ruling on January 30, 2018. The appellate court agreed that the prosecution met its burden of proof, establishing that Barrion was apprehended during a buy-bust operation and that the chain of custody for the seized evidence was intact.
Chain of Custody Requirements
The ruling emphasized the critical importance of maintaining the chain of custody for the seized drugs, requiring that the identity and integrity of the evidence be established with moral certainty. The law mandates immediate marking, inventory, and photography of seized items, preferably in the presence of the accused, their counsel, and independent witnesses such as media representatives or elected officials to prevent any suspicion regarding the evidence's integrity.
Non-Compliance with Chain of Custody
A key issue arose regarding the requirement for witness presence during the evidentiary procedures. The Court noted that the inventory and photography of the drugs did not include a media representative, which is a deviation from the established protocols. The absence of proper justification for this lapse, coupled with the failure to demonstrate genuine efforts to secure requisite witnesses, led to the conclusion that the integrity of the evidence was compromised.
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Case Background
- The appeal was filed by Rey Barrion y Silva, who was convicted of Illegal Sale of Dangerous Drugs under Republic Act No. 9165, also known as the "Comprehensive Dangerous Drugs Act of 2002."
- The Regional Trial Court (RTC) of Lipa City, Batangas, found Barrion guilty and sentenced him to life imprisonment and a fine of ₱500,000.00.
- The Court of Appeals (CA) affirmed the RTC's decision, leading to Barrion's appeal.
Facts of the Case
- An Information was filed against Barrion, alleging that on August 10, 2011, he was arrested during a buy-bust operation conducted by the Station Anti-Illegal Drugs Special Operation Task Group.
- During the operation, a plastic sachet containing a white crystalline substance was recovered from Barrion.
- The police officer, PO2 Dan Gonzales, marked the seized item at the arrest location and transported it to the police station, where it was placed in a larger sachet and marked again.
- The inventory of the seized item was conducted in the presence of a Department of Justice representative and a barangay councilor. The item was later confirmed to contain 0.04 grams of methamphetamine hydrochloride (shabu).
Accused's Defense
- Barrion denied the charges, claiming he was al