Case Summary (G.R. No. 228255)
Factual Antecedents
Mary Jane Cadiente y Quindo was charged with violating Sections 5 and 11 of Article II of RA 9165. The allegation arose from two incidents involving the sale and possession of methamphetamine hydrochloride (shabu) on July 9 and July 11, 2014, in Makati City. During the incidents, the accused allegedly sold and was found in possession of shabu without legal authorization.
Version of the Prosecution
The prosecution presented a case based on a buy-bust operation. A confidential informant alerted the authorities that the accused was involved in drug trafficking. Under police supervision, a legal buy-bust operation took place where the pin was given marked money with which the accused allegedly sold shabu. Subsequent searches revealed additional contraband, and the seized items were processed for evidence in accordance with police procedures.
Version of the Defense
The defense countered that the accused was the victim of police misconduct; she asserted that armed men abducted her and her family, later resulting in her wrongful detention and framing of drug charges when her family could not pay the ransom demanded for her release.
Ruling of the Regional Trial Court (RTC)
The RTC found the accused guilty beyond reasonable doubt for violating Section 5 of Article II of RA 9165, sentencing her to life imprisonment and a fine for the illegal sale of drugs. However, it acquitted her under Section 11 of Article II, citing insufficient evidence regarding her possession due to problems with witness testimony.
Ruling of the Court of Appeals (CA)
The CA upheld the RTC’s verdict, dismissing the defense’s argument regarding insufficient adherence to procedural requirements for the inventory of seized items. The CA concluded that despite minor procedural failures, the overall integrity of the operation and chain of custody was maintained, and thus affirmed the guilty verdict.
Supreme Court Ruling Analysis
Upon appeal, the Supreme Court found merit in the appellant’s claims, specifically regarding procedural compliance with Section 21 of RA 9165. The Court emphasized that both the physical inventory and photographic requirements must be fulfilled in the presence of requisite witnesses (media, DOJ representative,
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Case Reference
- G.R. No. 228255
- Date of Decision: June 10, 2019
- Court: Supreme Court of the Philippines
- Division: First Division
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Mary Jane Cadiente y Quindo @ Jane
Procedural History
- The appellant, Mary Jane Cadiente, appeals the Decision of the Court of Appeals dated April 29, 2016, which affirmed the Regional Trial Court's (RTC) Decision of December 10, 2014.
- The RTC found the appellant guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act (RA) No. 9165 (The Comprehensive Dangerous Drugs Act of 2002) and acquitted her of a separate charge under Section 11 of the same Act.
Factual Antecedents
- Charges Filed:
- Criminal Case No. 14-1089: Violation of Section 5, Article II of RA 9165 for selling shabu on July 11, 2014.
- Criminal Case No. 14-1090: Violation of Section 11, Article II of RA 9165 for possession of shabu on July 9, 2014.
- Appellant's Plea: Not guilty to both charges.
Version of the Prosecution
- A confidential informant reported the appellant's involvement in drug peddling.
- A buy-bust operation was conducted by the Makati police, where:
- PO2 Rexell Gabelo was designated as the poseur-buyer.
- The appellant was approached for the sale of shabu, leading to the transaction.
- The marked money was recovered along with additional sachets of shabu from the appellant.
- The inventory of seized items was conducted at a barang