Case Summary (G.R. No. 223556)
Background of the Case
Four Informations were filed against Ching, alleging violations related to drug possession, possession of drug paraphernalia, illegal sale of drugs, and maintenance of a drug den on June 29, 2003. Specifically, Criminal Case No. C-3522 highlighted possession of shabu, Case C-3523 involved possession of drug paraphernalia, and Case C-3533 concerned the illegal sale of shabu. These charges stemmed from a police operation where a buy-bust was conducted resulting in Ching's arrest.
Prosecution Evidence
During the operation on June 29, 2003, a buy-bust team, after conducting surveillance and a test-buy, arrested Ching following a purchase of shabu. Subsequent searches at his residence led to the recovery of additional shabu and drug paraphernalia. The bu-bust operation included the marking and inventory of the seized items, which were further submitted for chemical analysis confirming their illegal nature.
Defense's Position
Ching pleaded not guilty and presented a defense claiming misidentification and personal grievances against the arresting officer. He argued that the police fabricated evidence against him and did not adhere to the necessary legal procedures during the operation.
RTC Ruling
The Regional Trial Court (RTC), in a decision dated June 17, 2013, found Ching guilty on charges related to illegal possession of shabu and illegal sale of drugs while acquitting him of maintaining a drug den. A range of penalties, including life imprisonment and fines, were imposed based on the convictions in criminal cases C-3522, C-3523, and C-3533.
CA Ruling
The Court of Appeals upheld the RTC's ruling on June 30, 2015, affirming all convictions and asserting that the prosecution met the necessary burden of proof and established the chain of custody of the seized evidence. It discounted Ching’s claims of police misconduct as devoid of credible support.
Issue for Resolution
The central issue presented for the Supreme Court's review was whether Ching was guilty beyond reasonable doubt of the aforementioned charges under the Comprehensive Dangerous Drugs Act.
Supreme Court’s Analysis
The Supreme Court reiterated that an appeal in criminal cases allows for a comprehensive review of the evidence and procedural compliance. It highlighted the need for strict adherence to the chain of custody rules as detailed in Section 21 of RA 9165, asserting that the integrity of the evidence is crucial for establishing the corpus delicti.
Breach of Chain of Custody
The Court raised concerns about the failures in the chain of custody during the evidence handling process. Notably, it pointed out gap
...continue readingCase Syllabus (G.R. No. 223556)
Case Background
- This case involves an ordinary appeal assailing the Decision dated June 30, 2015, of the Court of Appeals (CA) in CA-G.R. CR-HC No. 01724.
- The CA upheld the Decision dated June 17, 2013, of the Regional Trial Court (RTC) of Catarman, Northern Samar, Branch 19, which found Manuel Lim Ching guilty beyond reasonable doubt of violating the Comprehensive Dangerous Drugs Act of 2002 (RA No. 9165).
Charges Against the Accused
- Ching was charged in four Criminal Cases:
- Criminal Case No. C-3522: Illegal possession of shabu (0.2 grams worth P300.00 and 0.2 grams worth P500.00, plus additional 5.3 grams).
- Criminal Case No. C-3523: Illegal possession of drug paraphernalia (23 aluminum foils, 6 improvised tooters, etc.).
- Criminal Case No. C-3533: Illegal sale of shabu (two sachets weighing a total of 0.4 grams valued at P800.00).
- Criminal Case No. C-3524: Maintenance of a drug den (acquitted on reasonable doubt).
Facts of the Case
- The prosecution alleged that on June 29, 2003, police conducted surveillance and a test-buy leading to a buy-bust operation at Ching’s residence.
- Ching was arrested after selling a sachet of shabu to a poseur-buyer.
- A subsequent search yielded additiona