Title
People vs. Constantino, Jr. y Binayug
Case
G.R. No. 199689
Decision Date
Mar 12, 2014
Accused acquitted due to broken chain of custody and inconsistent testimonies in a buy-bust operation involving illegal drug sale.

Case Summary (G.R. No. 199689)

Background of the Case

Hermanos Constantino was charged with the illegal sale of methamphetamine hydrochloride (shabu) under Article II, Section 5 of Republic Act No. 9165, referred to as the Comprehensive Dangerous Drugs Act of 2002. The Information filed against him alleged that he engaged in the sale of two sachets of shabu to a police officer acting as a poseur-buyer, resulting in his apprehension.

Procedural History

After being arrested and charged, Constantino was arraigned on July 8, 2005, where he pleaded not guilty. The trial proceeded, with the prosecution presenting testimonies, beginning with Police Superintendent Mariano Rodriguez, who organized the buy-bust operation following a tip from a confidential informant about Constantino’s drug activity.

Prosecution's Evidence

The prosecution's evidence detailed the unlawful transaction on January 20, 2005. A buy-bust team was organized, and police officers recorded the serial numbers of the marked money, which was then used to conduct the purchase of shabu. The evidence showed that Constantino was observed exchanging the money for two sachets of shabu. The arrested suspect subsequently could not refute the tamper-proof chain of evidence leading back to the drugs being analyzed by a forensic chemist.

Constantino's Defense

Constantino, in his defense, posited that he was a victim of a police setup and recounted an alleged joyride with a friend before his arrest. He contended that the police had wrongfully accused him, forcing him to comply under duress while they fabricated evidence against him.

Trial Court's Findings

The RTC ruled against Constantino, convicting him on April 15, 2008. It concluded that the prosecution had sufficiently demonstrated the essential elements of the crime, including the identity of the buyer and seller, the transaction, and the delivery of the illegal object. The trial court rejected the defense's claims of irregularities and upheld the compliance of the police with necessary procedures, including the chain of custody of the confiscated illegal drugs.

Appeal to the Court of Appeals

Constantino appealed the RTC's decision, arguing that the court had erred in fully endorsing the testimony of prosecution witnesses in light of alleged procedural irregularities and failures to establish a credible chain of custody for the confiscated drugs. The Court of Appeals affirmed the RTC's decision, reasoning that Constantino had been caught in the act, and thus the evidence against him remained intact.

Supreme Court's Analysis

In reviewing the case, the Supreme Court found significant inconsistencies impacting the chain of custody of the evidence, essential in confirming the integr

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