Case Summary (G.R. No. 243664)
Case Background
Accused-appellant Jocel BaAares De Dios was charged with Illegal Sale (Criminal Case No. T-5869) and Illegal Possession (Criminal Case No. T-5870) of Dangerous Drugs, specifically methamphetamine hydrochloride, commonly known as "shabu." The Regional Trial Court of Tabaco City found him guilty beyond reasonable doubt. The prosecution's case stemmed from a buy-bust operation conducted on June 5, 2014, where police seized plastic sachets containing shabu from the accused-appellant.
Prosecution's Evidence
During the operation, a poseur-buyer from the Tabaco City Police Station made a successful purchase of shabu from accused-appellant, which was subsequently seized along with additional contraband during a follow-up search. Items were marked, inventoried, and photographed immediately after confiscation, in compliance with legal requirements. The evidence was subjected to a laboratory examination, confirming the substance as a prohibited drug.
Accused-Appellant's Defense
In his defense, the accused-appellant denied the charges, claiming that he was unjustly arrested while waiting for a pedicab. He alleged that the drugs were planted on him by law enforcement officers who were previously acquainted with him due to a prior, unrelated with insufficient evidence. This defense relied heavily on his own testimony, lacking corroborative evidence.
Regional Trial Court's Decision
The Regional Trial Court, in its August 1, 2016 decision, found the accused-appellant guilty of both charges and handed down severe penalties: life imprisonment and a fine of P500,000.00 for the sale of drugs, and a twelve-year and one-day to fourteen-year term with a P300,000.00 fine for possession. The RTC cited the credibility of the prosecution witnesses and the failure of the accused-appellant’s defense, which was deemed self-serving and unsubstantiated.
Court of Appeals Review
The accused-appellant appealed to the Court of Appeals, which upheld the RTC's finding in a decision dated May 23, 2018. The appellate court agreed that the prosecution successfully established all elements of the alleged offenses, reinforcing the findings and interpretations made by the trial court.
The Court's Ruling on Appeal
In affirming the lower courts' decisions, the higher court reiterated that the elements for Illegal Sale and Possession under Sections 5 and 11 of the Comprehensive Dangerous Drugs Act had been proven. It emphasized the clear and convincing evidence of the drug buy-bust procedure and the legitimacy of the search that followed.
Chain of Custody Compliance
The court highlighted the importance of the chain
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Overview of the Case
- The case concerns the ordinary appeal filed by Jocel BaAares De Dios, also known as "Tata," against the Decision of the Court of Appeals dated May 23, 2018.
- The Court of Appeals affirmed the Regional Trial Court's (RTC) ruling issued on August 1, 2016, which found the accused guilty beyond reasonable doubt of violating Sections 5 and 11, Article II of Republic Act No. 9165, known as the "Comprehensive Dangerous Drugs Act of 2002."
Factual Background
- The case originated from two Informations filed against the accused-appellant for Illegal Sale and Illegal Possession of Dangerous Drugs.
- On June 5, 2014, a buy-bust operation was conducted by the Tabaco City Police Station, which led to the arrest of the accused-appellant.
- During the operation, one heat-sealed plastic sachet containing 0.024 gram of a white crystalline substance was recovered from him, and further searches yielded two more sachets of suspected shabu.
- The seized items were marked, inventoried, and photographed at the scene of the arrest in the presence of a media representative, a DOJ representative, a barangay official, and the accused-appellant.
Defense of the Accused
- The accused-appellant denied the charges, asserting that he was wrongfully arrested while waiting for a pedicab.
- He claimed that the police officer handcuffed him and later planted evidence, alleging that the items found were handed to the police by an