Case Summary (G.R. No. 233883)
Case Background
This case arises from three Informations filed against Mark Vincent Corral y Batalla, accusing him of Illegal Sale and Illegal Possession of Dangerous Drugs, following a buy-bust operation conducted by the Calamba City Police Station on August 24, 2013. The operation resulted in the recovery of two sachets of a white crystalline substance, which tested positive for methamphetamine hydrochloride, also known as shabu.
Proceedings in Lower Courts
The RTC, in its ruling dated March 31, 2016, convicted the accused-appellant of Illegal Sale of Dangerous Drugs, imposing a penalty of life imprisonment and a fine of PHP 500,000.00, while acquitting him of Illegal Possession due to insufficient evidence. The trial court upheld the integrity of the seized items, supported by the conduct of a buy-bust operation and the subsequent handling of the evidence.
Appeal and Court of Appeals Ruling
The accused-appellant's appeal to the CA resulted in an affirmation of the RTC's ruling on April 21, 2017. The CA concluded that the prosecution complied with the chain of custody requirements, relying on the testimonies of the police officers involved in the operation.
Legal Issue Presented
The primary legal issue to be resolved by the Supreme Court was whether the CA correctly upheld the conviction of the accused-appellant for Illegal Sale of Dangerous Drugs.
Supreme Court's Ruling
The Supreme Court granted the appeal, asserting that the prosecution failed to establish the integrity of the seized drugs. To maintain a conviction for Illegal Sale or Possession of Dangerous Drugs under RA 9165, it is necessary to demonstrate the identity of the drugs with moral certainty, as they constitute the corpus delicti of the crime.
Chain of Custody Requirements
The Court emphasized that strict compliance with the chain of custody procedure is essential. Marking, inventorying, and photographing the seized items must occur immediately following their seizure. The law necessitates that such procedures be executed in the presence of certain witnesses, including representatives from the media and the Department of Justice, to ensure transparency and prevent evidence tampering.
Procedural Deviations and Consequences
In this case, the inventory and photography of the seized drugs occurred without the required witnesses from the media and the DOJ. The testimonies from police of
...continue readingCase Syllabus (G.R. No. 233883)
Case Background
- This case arises from an appeal concerning the decision of the Court of Appeals (CA) affirming the Regional Trial Court (RTC) ruling in the case of Mark Vincent Corral y Batalla.
- The RTC found the accused-appellant guilty of the Illegal Sale of Dangerous Drugs, specifically methamphetamine hydrochloride (shabu), under Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002.
- The RTC sentenced the accused-appellant to life imprisonment and a fine of ₱500,000.00, while acquitting him of Illegal Possession of Dangerous Drugs due to insufficient evidence.
The Facts of the Case
- The prosecution's case was built on three Informations filed before the RTC, charging the accused-appellant with Illegal Sale and Illegal Possession of Dangerous Drugs and drug paraphernalia.
- On August 24, 2013, during a buy-bust operation at around 6:30 p.m., police officers arrested the accused-appellant and recovered two small plastic sachets containing 0.03 grams and 0.18 grams of white crystalline substances, later confirmed to be shabu.
- Additional drug paraphernalia, including aluminum foil and a glass tooter, was discovered during the search of the accused-appellant's residence.
- The arresting officers conducted marking, inventory, and photography of the seized items at the barangay hall in the presence of the Barangay Captain.
Accused-Appellant's Defense
- The accused-appellant presented a defense of denial and claimed that he was at home caring for his children when police officers forcibly entered his home and arrested him without just cause.
- He alleged that he was punched, searched, and coerced into revealing informa