Case Summary (G.R. No. 195777)
Background of the Case
On July 14, 2003, Castro pleaded not guilty to charges of illegal sale and illegal possession of shabu before the Regional Trial Court of Pasig City. During the pre-trial phase, certain facts concerning the genuineness of the laboratory examination requests and report were stipulated by both parties, eliminating the need for the prosecution's witness, Forensic Chemist Sr. Police Inspector Annalee R. Forro, to testify.
Prosecution's Case
The prosecution's narrative was established through the testimonies of PO1 Allan Mapula and PO1 Michael Familara, members of the Drug Enforcement Unit. On May 7, 2003, they received information from a confidential informant regarding Castro selling illegal drugs in Barangay Manggahan, Pasig City. A buy-bust operation was organized, during which a marked P100 bill was provided as buy-bust money. The officers executed the operation successfully, leading to the arrest of Castro, who was found to be in possession of methamphetamine.
Defense's Case
In contrast, the defense presented testimonies from Castro himself and two witnesses, Arthur Millare and Romeo dela Cruz, who claimed that Castro was merely confronted by police officers after a drinking session with friends and was unjustly arrested. They opined that the police did not provide justification for Castro's arrest and accused them of misconduct.
Trial Court's Decision
After evaluating both parties' arguments, the trial court found Castro guilty beyond reasonable doubt of violating Sections 5 and 11 of RA 9165. The court sentenced him to life imprisonment for the illegal sale of shabu and modified the penalty for illegal possession of shabu from the original sentence to 12 years and 1 day minimum to 14 years and 8 months maximum, along with a fine.
Appeal and the Court of Appeals
Castro appealed the decision, arguing that the testimonies of witnesses from both sides were self-serving, the warrantless arrest was invalid, and the seized items should thus be considered inadmissible. The Court of Appeals affirmed the trial court’s decision with modifications regarding penalties but upheld the legality of the arrest and the sufficiency of evidence presented by the prosecution.
Legal Principles Involved
To secure a conviction under the statute, the prosecution needed to establish the sale's identity, the object of the sale, and that the drugs were illicitly sold and possessed. This was corroborated by credible police testimonies and the forensic findings indicating that the substance was methamphetamine. On the other hand, the defense's invocation of the equipoise rule was deemed inapplicable due to the robust credibility of the prosecution witnesses, whose testimonies were consistent and detailed.
Chain of Custody
Despite the defens
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Case Overview
- The case revolves around the conviction of Ferdinand Castro y Lapena for violating Sections 5 and 11, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002).
- The Court of Appeals affirmed the trial court's decision, finding him guilty beyond reasonable doubt for illegal sale and illegal possession of methamphetamine hydrochloride (shabu), with modifications to the penalties.
Facts of the Case
- On July 14, 2003, accused-appellant pleaded "not guilty" to charges of illegal sale and illegal possession of shabu before the Regional Trial Court of Pasig City.
- During pre-trial, the prosecution's key witness, Forensic Chemist Sr. Police Inspector Annalee R. Forro, was not presented due to stipulations between the parties regarding the authenticity of laboratory documents and the existence of the seized plastic sachets.
- The prosecution's narrative indicates that on May 7, 2003, PO1 Michael Familara received information from a confidential informant about "Fredie" (the accused) selling illegal drugs at Kalamansi Street, Pasig City, leading to the formation of a buy-bust team.
- The team marked a P100 bill as buy-bust money and proceeded to the location where the informant introduced PO1 Familara as a buyer to the accused, culminating in the sale of a plastic sachet of shabu.
- The police officers arrested the accused after the transaction, finding additional sachets of shabu and the marked money in h