Case Summary (G.R. No. 235469)
Case Background
Abdullah Dalupang was charged for the illegal sale and possession of dangerous drugs under the Comprehensive Dangerous Drugs Act of 2002. The Regional Trial Court (RTC) of Lanao del Norte, after a joint trial of two consolidated cases, found Dalupang guilty and imposed life imprisonment and substantial fines on him. The Court of Appeals upheld this decision, prompting Dalupang to appeal.
Prosecution's Evidence
The buy-bust operation occurred on May 1, 2014, where an undercover agent, IO2 Pamisa, utilized a P500 marked bill to procure shabu from Dalupang. The operation involved a pre-arranged team led by IO4 Recites, where an informant identified Dalupang as the seller. After the transaction, PDEA agents, acting on a pre-arranged signal, arrested Dalupang and seized various sachets of shabu from his vehicle.
Defense's Claims
Dalupang's defense claimed that he was a victim of an illegal arrest, asserting that no buy-bust occurred and that the police testimonies were inconsistent. The defense witnesses posited that Dalupang was accosted without due process, with suggestions of coercion by the authorities.
RTC Findings
In its March 16, 2016 decision, the RTC concluded that the prosecution had established beyond reasonable doubt that Dalupang was guilty of both illegal sale and possession, citing the strength of the testimonies from law enforcement officials and the chain of custody maintained despite the defense's assertions.
Court of Appeals Decision
The Court of Appeals, affirming the RTC's ruling, emphasized that Dalupang was caught in the act and that the procedural protocols followed by law enforcement were adequate, specifically regarding the validity of the seizure of evidence and the application of the plain view doctrine.
Main Legal Issue
The primary issue on appeal was whether Dalupang's guilt was proven beyond reasonable doubt, particularly focusing on the adherence to legal mandates involving the seizure and inventory of confiscated drugs, specifically the requirement for three witnesses.
Court's Ruling
The Court acquitted Dalupang due to the failure of law enforcement to comply with the "three-witness rule" as mandated by Section 21 of R.A. No. 9165. It was
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Case Overview
- This case is an appeal by Abdullah Dalupang y Dimangadap against the Decision of the Court of Appeals-Cagayan de Oro, which affirmed the Joint Decision of the Regional Trial Court (RTC) of Lanao del Norte convicting him of illegal sale and possession of dangerous drugs under Republic Act (R.A.) No. 9165.
- The appeal was filed following the RTC's conviction and sentencing of Dalupang to life imprisonment and substantial fines.
Factual Background
- On May 2, 2014, two Informations were filed against Dalupang for violation of Sections 5 and 11 of R.A. No. 9165—illegal sale and possession of shabu, respectively.
- The two cases were consolidated and tried jointly in the RTC of Lanao del Norte, Branch 6.
- The prosecution's case was built on the testimony of five witnesses, including PDEA agents and a media representative.
The Buy-Bust Operation
- A confidential informant reported Dalupang's alleged drug activity, leading to a buy-bust operation where P500.00 was used to purchase shabu.
- The operation occurred on May 1, 2014, where Dalupang was identified and arrested after selling a sachet of shabu to the poseur-buyer, Pamisa.
- The arresting officers found additional sachets of shabu in Dalupang's v