Case Summary (G.R. No. 254259)
Background of the Case
In an Amended Information filed with the Regional Trial Court (RTC), Bangcola and his co-accused, Salim Lala Pimba, were charged under Section 5 and Section 11 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The charges were based on an operation that took place on June 20, 2014, in which Bangcola allegedly sold and possessed methamphetamine hydrochloride, also known as shabu.
Trial Proceedings
During the trial, Bangcola pleaded not guilty, while Pimba remained at large. The prosecution's evidence relied heavily on the testimony of SPO1 Basang and forensic reports confirming the presence of illegal drugs. The buy-bust operation was organized after a tip-off from a confidential informant indicated Bangcola's involvement in illegal drug activities.
Prosecution's Evidence
The prosecution claimed that during the buy-bust operation, SPO1 Basang, acting as a poseur buyer, successfully purchased illegal drugs from Bangcola. The operation involved marked bills used for the transaction, after which Bangcola was apprehended with additional sachets of drugs in his possession. The prosecution documented the seizure and subsequent inventory at the Barangay Hall due to safety concerns and poor visibility at the arrest location.
Defense Argument
Bangcola's defense centered on asserting his innocence, claiming he was wrongfully accused and emphasizing discrepancies in the prosecution's evidence. The defense pointed to the lack of proper inventory protocols and the absence of certain required witnesses from the Department of Justice (DOJ) during evidence handling, which they argued compromised the integrity of the evidence.
RTC and CA Rulings
The RTC ruled that the prosecution established Bangcola's guilt and imposed heavy sentences for both the sale and possession of drugs. The RTC accepted the explanations for not completing the inventory at the arrest site and concluded that the chain of custody was sufficiently maintained. However, Bangcola appealed, and the Court of Appeals (CA) upheld the RTC's decision, stating that the prosecution satisfactorily proved all elements of the crimes charged.
Supreme Court's Analysis
Upon reviewing the appeal, the Supreme Court reiterated the principles of the presumption of innocence and the burden of proof placed on the prosecution. The Court emphasized that the elements of illegal sale and possession of drugs must be thoroughly established, including strict adherence to the chain of custody requirements outlined in R.A. No. 9165.
Chain of Custody Issues
The Court identified several procedural deficiencies in the prosecutio
...continue readingCase Syllabus (G.R. No. 254259)
Background of the Case
- This case involves an appeal to reverse the January 3, 2018 Decision of the Court of Appeals (CA) affirming the Regional Trial Court (RTC) judgment that found Macmac Bangcola y Maki guilty of illegal sale and possession of dangerous drugs.
- The charges stemmed from incidents occurring on June 20, 2014, in Marikina City, where Bangcola was accused of selling and possessing methamphetamine hydrochloride (shabu).
Charges Filed
- Appellant Bangcola and co-accused Salim Lala Pimba were charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
- A separate charge was filed against Bangcola for illegal possession of dangerous drugs under Section 11, Article II of the same law.
- The prosecution alleged that Bangcola sold one heat-sealed plastic sachet containing 0.20 grams of shabu and possessed thirteen sachets containing a total of 34.12 grams of the same substance.
Prosecution's Evidence
- The prosecution presented evidence including the testimony of Senior Police Officer I Deogracias Basang, who participated in a buy-bust operation.
- A confidential informant reported Bangcola's drug activities, leading to the formation of a buy-bust team.
- During the operation, marked bills were used, and upon successful completion of the sale, Bangcola was arrested, and various items, including the drugs and cash, were confiscated.
- The drugs were subjected to laboratory examination, confirming t