Case Summary (G.R. No. 242880)
Factual Background
On August 7, 2015, law enforcement conducted a buy-bust operation against Dadang based on information from a confidential informant about his drug selling activities. The operation included preparations and the use of marked money. During the operation, Dadang was apprehended after allegedly selling shabu to a poseur-buyer, identified as Police Officer 3 Cyrus Baillo. Upon entering Dadang’s rented room at Jerggy's Inn, officers discovered not only the illicit drugs but also drug paraphernalia, resulting in multiple charges against Dadang under Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
Charges and Convictions
Dadang was charged with three counts of offenses: illegal sale of dangerous drugs under Section 5, illegal possession of dangerous drugs under Section 11, and illegal possession of drug paraphernalia under Section 12 of R.A. No. 9165. On March 28, 2017, the Regional Trial Court (RTC) found him guilty beyond reasonable doubt on all counts, sentencing him to life imprisonment for the sale of drugs, imprisonment for 12 years and 1 day to 20 years for possession of drugs, and imprisonment for 6 months and 1 day to 4 years for possession of paraphernalia.
Court Proceedings and Appeal
Following the RTC’s verdict, Dadang appealed to the Court of Appeals, which upheld the lower court’s decision on August 30, 2018. The Court of Appeals affirmed the findings of fact, concluding that the prosecution convincingly established all elements of the illegal sale and possession charges. It also confirmed the continuity of the chain of custody over the seized drugs, which allowed the evidence to maintain its integrity.
Elements of the Charges
For a conviction of illegal sale under Section 5, the prosecution must demonstrate that (1) a transaction occurred involving the sale of illegal drugs, (2) the illicit substance was presented in court, and (3) the identities of the buyer and seller were established. As for illegal possession under Section 11, three elements must be proven: (1) possession of an illicit item, (2) such possession is unauthorized by law, and (3) the accused knowingly possessed the drug. Similarly, for Section 12, it must be demonstrated that the accused possessed drug paraphernalia without legal authorization.
Evidence and Chain of Custody
The evidence presented showed the meticulous unfolding of the buy-bust operation, including testimony from law enforcement officers and the recovered items. During the operation, the officers conducted an inventory of the seized materials, which were later submitted for laboratory examinations, confirming the presence of shabu. The Court underscored the importance of adhering to legal mandates on the chain of custody, noting that procedures were followed to ensure the integrity of the evidence collected during Dadang's ar
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Case Overview
- The case involves Quisar Arances Dadang, accused of illegal sale and possession of dangerous drugs and drug paraphernalia under Republic Act No. 9165.
- The appeal stems from the August 30, 2018 Decision of the Court of Appeals-Cagayan de Oro City, affirming the Regional Trial Court's (RTC) March 28, 2017 Decision.
Background of the Case
- The accused, Quisar Arances Dadang, was charged with three counts of violating Sections 5 (Illegal Sale), 11 (Illegal Possession of Dangerous Drugs), and 12 (Illegal Possession of Drug Paraphernalia) of Article II of R.A. No. 9165.
- The charges arose from a buy-bust operation conducted on August 7, 2015, by the Cagayan de Oro City Anti-Illegal Drug Task Force (CAIDTF) in collaboration with the Philippine Drug Enforcement Agency (PDEA).
Details of the Buy-Bust Operation
- The operation was initiated based on information from a confidential informant (CI) about a person known as "Manoy," later identified as Dadang, selling illegal drugs.
- The buy-bust team, led by PO3 Cyrus Baillo and SPO1 Rene Destura, prepared marked money amounting to P1,000.00 for the operation.
- At approximately 5:30 PM, the team arrived at Jerggy's Inn, where Dadang was staying. The CI knocked on the door, and Dadang allowed them entry without verifying their identities.
Evidence Collected During the Operation
- Inside Dadang's room, law enforcement discovered various drug paraphernalia including improvised aluminum foil, an improvised glass pipe, a lighter, and a digital weighing scale.
- The CI signaled the completion of the sale by handi