Case Summary (G.R. No. 243386)
Facts of the Case
Two separate informations were filed against De Castro: Criminal Case No. 10-501 for illegal possession of dangerous drugs, and Criminal Case No. 10-502 for illegal sale of dangerous drugs. Both incidents occurred on August 4, 2010, in Muntinlupa City, where De Castro was apprehended in possession of a total of 0.14 grams of Methylamphetamine Hydrochloride, known as shabu, contained in multiple plastic sachets.
Prosecution's Version
The prosecution's case relied on multiple witnesses, including police officers and forensic chemists who participated in a buy-bust operation. The operation was purportedly initiated after receiving information about De Castro's illegal drug activities. During the operation, De Castro allegedly sold shabu to a poseur-buyer and was found in possession of additional drugs when apprehended. Despite procedural documentation being in place, the prosecution had to navigate the sensitivities of law enforcement conduct during such operations.
Defense's Version
De Castro, as the sole witness for his defense, claimed he was wrongfully arrested. He asserted that his apprehension occurred on August 3, 2010, and that he was searched without cause by police officers who failed to find any illegal substances initially. This version aimed to undermine the prosecution's narrative by arguing against the timeline of events and the legality of the evidence against him.
Ruling of the Regional Trial Court (RTC)
The RTC found De Castro guilty, ruling that the prosecution had successfully established all elements of the charges against him. It pointed out that the buy-bust operation was conducted in accordance with legal standards, although procedural requirements related to evidence handling were acknowledged.
Ruling of the Court of Appeals (CA)
The CA affirmed the RTC's ruling, stating that all elements of the charges were proven beyond a reasonable doubt. However, it noted procedural deficiencies regarding compliance with evidence handling laws, particularly the requirements set forth under Section 21 of RA 9165.
Issue at Stake
The central issue involved whether De Castro's guilt for violation of Sections 5 and 11 of RA 9165 was proven beyond reasonable doubt, particularly given the procedural lapses noted during the law enforcement process.
The Court's Ruling
Upon appeal, the Court granted De Castro's acquittal, emphasizing the critical nature of maintaining the integrity and identity of the corpus delicti in drug-related offenses. The
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Case Reference
- Citation: 861 Phil. 92
- Division: SECOND DIVISION
- Case Number: G.R. No. 243386
- Date: September 02, 2019
Overview
- This case involves an appeal under Section 13(c), Rule 124 of the Rules of Court from the Decision dated February 6, 2018, of the Court of Appeals (CA) in CA-G.R. CR-HC. No. 07962.
- The CA's decision affirmed the Regional Trial Court's (RTC) ruling, which found the accused-appellant Hilario De Castro y Santos alias "Dacoy" guilty of violating Sections 5 and 11, Article II of Republic Act No. (RA) 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
Charges Against the Accused
Criminal Case No. 10-501: Illegal Possession of Dangerous Drugs
- Date: August 4, 2010
- Location: Muntinlupa City
- Details: De Castro was found in possession of 0.12 grams of Methylamphetamine Hydrochloride (shabu) in two sachets.
Criminal Case No. 10-502: Illegal Sale of Dangerous Drugs
- Date: August 4, 2010
- Location: Muntinlupa City
- Details: De Castro sold 0.02 grams of Methylamphetamine Hydrochloride (shabu) contained in one sachet.
Procedural History
- De Castro pleaded not guilty upon arraignment.
- The prosecution presented multiple witnesses, including police officers and forensic chemists, providing evidence of the buy-bust operation.
- The defense presented De Castro's testimony, claiming he was wrongfully arrested.
Version of the Prosecution
- The prosecution's presentation included:
- Buy-Bust Operation: Initiated at 2:00 a.m. on August 4, 2010, based on a tip-off regarding De Castro selling shabu.
- Execution: A police team, including PO3 Amodia as the poseur-buyer, engaged De Castro in a controlled transaction for P300 worth of shabu.
- Arrest and Seizure: Following the transaction, De Castro was arrested, and two additional sachets of shabu were retrieved from his possession.
- Documentation: The