Case Summary (G.R. No. 217661)
Facts of the Case
The Information against Buniag indicated that on August 9, 2008, he was accused of knowingly selling marijuana to a poseur-buyer, which was a violation of the aforementioned law. A detailed account of the events noted that a buy-bust operation was conducted by agents from the Philippine Drug Enforcement Agency (PDEA), during which Buniag was arrested while attempting to sell marijuana packaged in bags.
Prosecution's Version
The prosecution presented a narrative wherein PDEA agent IO1 Rubylyn S. Alfaro, accompanied by a confidential informant, arranged a drug purchase from Buniag. The agents conducted surveillance and identified Buniag at the agreed location. During the transaction, upon Alfaro's prearranged signal, other officers intervened and arrested Buniag, retrieving the black bag containing three bundles of marijuana. Subsequent testing confirmed the substance as marijuana, documented under a chemical report.
Defense's Version
Buniag denied the allegations, asserting a complete lack of involvement with the drugs. He claimed that he was in Cagayan de Oro City merely to check on his brother's house at the latter’s request. He alleged that he was ambushed by the PDEA agents with no lawful reason and suggested that the officers sought a bribe for his release, which he could not afford.
Ruling of the RTC
On December 23, 2013, the RTC ruled against Buniag, asserting that the prosecution had effectively met the burden of proof necessary to establish his guilt for the attempt to sell dangerous drugs. The court concluded that even though the exchange of money had not occurred prior to arrest, Buniag was culpable for possessing and delivering the marijuana. Consequently, he was sentenced to life imprisonment and imposed a fine of Php 500,000, with the seized drugs ordered for forfeiture.
Ruling of the CA
The Court of Appeals upheld the RTC decision on January 30, 2015, noting that Buniag had clearly intended to sell the drugs, and the prosecution had sufficiently demonstrated the attempt. Although the RTC had initially identified Buniag's conviction under Section 5, the CA modified the ruling to align it with Section 26(b), noting the failed attempt to complete the sale did not preclude his liability for attempted illegal sale.
Issue on Appeal
The central issue on appeal was whether the CA erred in affirming Buniag's guilt for violating Section 26(b) of RA 9165.
Court's Ruling
The appellate court found merit in Buniag's appeal, determining that, while the prosecution could legitimately argue that an attempt to sell had occurred, the proceedings showed significant procedural failings that necessitated his acquittal. Notably, the requirement for establishing the corpus delicti was unmet due to the failure of law enforcement to comply with strict evidence preservation protocols as mandated by Section 21 of RA 9165. The ruling underscored the importance of maintaining a clear chain of custody from the time of seizure through to the court presentation of evidence.
Procedural Violations and Their Impact
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...continue readingCase Syllabus (G.R. No. 217661)
Case Overview
- The case involves an appeal from the Decision dated January 30, 2015, of the Court of Appeals (CA) affirming the Regional Trial Court's (RTC) Judgment dated December 23, 2013.
- The accused-appellant, Ferdinand Buniag y Mercadera, was found guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002.
- The decision was rendered by Justice Caguioa and the ruling is significant in the context of drug-related offenses and the procedural requirements surrounding the chain of custody of seized items.
Facts of the Case
- An Information was filed against Buniag, alleging that on August 9, 2008, he sold marijuana without legal authorization in Cagayan de Oro City.
- Buniag was arraigned and pleaded not guilty.
- The prosecution's account described a buy-bust operation where PDEA Agent IO1 Rubylyn S. Alfaro, posing as a buyer, arranged to purchase Php 5,000 worth of marijuana from Buniag.
- The operation occurred at around 7:30 PM, where Buniag presented the marijuana concealed in a black traveling bag.
- Upon confirming the presence of the drugs, the police arrested Buniag.
- Evidence collected included three bundles of marijuana weighed and marked by law enforcement officers.
Prosecution's Version
- The prosecution detailed the surveillance and planning leading to the buy-bust operation.
- IO1 Alfaro and her team executed the operation at the pre-arranged time and location.
- The marijuana was inspected before the arrest, and proper documentation was prepared post-arrest.
- Chemistry report confirmed that the substances were inde