Case Summary (G.R. No. 230065)
Charges Against the Accused
Crispo and Herrera were charged with two separate but related offenses: Illegal Sale of Dangerous Drugs under Crim. Case No. 12-293828 and Illegal Possession of Dangerous Drugs under Crim. Case No. 12-293829. The materials involved included methamphetamine hydrochloride, commonly known as "shabu," with specific weights enumerated in the complaint.
Factual Background
On November 19, 2012, the Manila Police District Station 4 conducted a buy-bust operation based on information from a confidential informant about illegal drug activities involving Crispo. During the operation, Crispo allegedly sold a sachet of shabu to a poseur buyer, Police Officer 2 Dennis Reyes, while Herrera acted as the intermediary. Following the transaction, Crispo was found in possession of additional sachets of shabu. The items were seized and later confirmed to contain methamphetamine by the crime laboratory.
Accused's Defense
Both accused-appellants pleaded not guilty. Crispo claimed that he was wrongfully arrested while en route to visit a relative, asserting that police threatened him into admitting guilt and offered to release him for a monetary payment. Herrera contended his arrest followed an accidental collision with a police vehicle and was accompanied by confusion regarding the signing of an affidavit.
RTC Ruling
On October 24, 2014, the RTC ruled against the accused-appellants, finding them guilty of the charges. Crispo received a life sentence for the illegal sale and an indeterminate sentence for possession, alongside fines. The court concluded the prosecution successfully established the elements of the crimes, rejecting the defense's narrative of innocence.
CA Ruling
The CA upheld the RTC's ruling in its March 17, 2016 decision, reinforcing that the prosecution had sufficiently proven its case. It deemed that the absence of representatives from the Department of Justice (DOJ) and media was not in itself a basis for dismissal, provided the integrity of the evidence was maintained.
Legal Issue
The primary issue presented for review is whether the CA correctly affirmed the convictions of the accused-appellants, particularly focusing on the procedural aspects of evidence handling that are crucial for drug-related cases.
Court's Ruling on Herrera's Death
During the appeal's pendency, the Court received notice of Herrera's death on April 3, 2017. The Court ruled that, under Article 89 of the Revised Penal Code, Herrera's criminal liability was extinguished, necessitating the dismissal of charges against him due to lack of a living defendant, thereby closing his case.
Court's Ruling on Crispo's Appeal
The Court evaluated Crispo’s appeal and found merit in his arguments. It stressed that an appeal opens the entire case for review and carries with it the obligation to scrutinize and address errors from previous rulings. The Court emphasized the prosecution's burden to establish not only the elements of the offense but also the integrity of the evidence, specifically the chain of custody regarding the drugs seized.
Importance of Chain of Custody
In drug-related convictions, ensuring an unbroken chain of custody for evidence is crucial. The law mandates certain procedures during the handling and presentation of seized drugs, intending to prevent tampering and maintain evidence integrity.
Procedural Lapses
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Case Overview
- This case involves an ordinary appeal filed by accused-appellants Marcelino Crispo y Descalso alias "Gogo" and Enrico Herrera y Montes against the Decision of the Court of Appeals (CA) dated March 17, 2016.
- The CA affirmed the Regional Trial Court (RTC) of Manila's Decision dated October 24, 2014, which found both accused-appellants guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act No. 9165, known as the "Comprehensive Dangerous Drugs Act of 2002."
- Crispo was additionally found guilty of violating Section 11, Article II of the same law.
Facts of the Case
- The case originated from two Informations filed before the RTC, charging the accused-appellants with:
- Crim. Case No. 12-293828: Illegal Sale of Dangerous Drugs.
- Crim. Case No. 12-293829: Illegal Possession of Dangerous Drugs (specifically against Crispo).
- On November 19, 2012, a confidential informant alerted the Manila Police District Station 4 about illegal drug activities involving Crispo at Ma. Cristina Street, Sampaloc, Manila.
- A buy-bust operation was organized, with PO2 Dennis Reyes acting as the poseur buyer. After approaching the accused, a transaction occurred wherein Herrera facilitated the sale of a sachet of shabu from Crispo to PO2 Reyes.
- Following the transaction, the accused were apprehended, and during a search, three additional sachets of shabu were recovered from Crispo.
- The items were inventoried and photographed in the presence of two barangay kagawads, with the chain of custody being a critical aspect of the prosecution’s case.
RTC Ruling
- The RTC ruled on October 24, 2014, finding both accused-appellants