Case Summary (G.R. No. 46739)
Applicable Law
The relevant legal framework for the case is Republic Act No. 9165, specifically Section 21, which governs the chain of custody for seized illegal drugs, ensuring that their integrity and evidentiary value are preserved throughout the apprehension and prosecution process.
The Proceedings Before the Trial Court
The charge against the appellants stemmed from a buy-bust operation on October 9, 2011, in Laoag City, where they allegedly sold methamphetamine hydrochloride, commonly known as "shabu." The prosecution presented several witnesses, including law enforcement officers who executed the operation. The defense, on the other hand, claimed unlawful arrest and presented testimonies to support their assertion.
Prosecution's Version
Under the prosecution's narrative, the police received a tip-off about Cacal selling shabu, leading to a buy-bust operation. After coordinating with a poseur buyer, PO1 Sugayen, they proceeded to the location, where De Vera allegedly delivered the drug to the buyer and received pay. Upon the completion of the operation, both appellants were arrested, and the drug was marked and submitted for forensic examination. The chemist confirmed that the substance was indeed methamphetamine.
Defense's Version
The defense argued that appellants were victims of police misconduct. Cacal claimed he was at the bar for a job interview, while De Vera testified that she was collecting money for her aunt. Both maintained that they had not engaged in any illegal activity and were falsely charged by corrupt police officers. Witness corroborations were provided to support their claims regarding their whereabouts and the nature of their interactions with law enforcement.
The Trial Court's Ruling
The trial court convicted both appellants, sentencing them to life imprisonment and imposing a fine of P500,000. The court relied heavily on the testimonies of the arresting officers and the confirmation from the forensic chemist regarding the nature of the seized substance.
The Court of Appeals' Ruling
Upon appeal, the appellants challenged the trial court's decision, insisting that there were significant procedural lapses during the buy-bust operation, particularly concerning the chain of custody of the seized drug. However, the appellate court upheld the conviction, asserting that the integrity of the evidence was adequately maintained despite procedural issues.
The Present Appeal
The appellants sought further relief, focusing on the alleged shortcomings in handling the chain of custody. The primary issue was whether the Court of Appeals erred in affirming the trial court’s ruling despite these claims.
Ruling on the Chain of Custody Issues
The higher court found that the prosecution had failed to maintain an unbroken chain of custody as mandated by RA 9165. Testimonies during the trial highlighted several procedural breaches, including the failure to mark the drug immediately at the scene of the arrest, the absence of a proper inventory conducted in the presence of required witnesses, and discrepancie
...continue readingCase Syllabus (G.R. No. 46739)
The Case
- This appeal seeks to reverse the decision dated January 04, 2016, of the Court of Appeals, which affirmed the conviction of appellants Donna Claire De Vera and Abigail Cacal y Valiente for violating Section 5, Article II of Republic Act No. 9165 (RA 9165).
- The case involves the sale and delivery of Methamphetamine Hydrochloride, commonly known as "Shabu," weighing 0.0415 grams, without the necessary license or authority.
The Proceedings Before the Trial Court
The Charge
- An Amended Information was filed against the appellants on October 14, 2011, detailing their alleged conspiracy to sell drugs on October 9, 2011, in Laoag City.
- The Regional Trial Court - Branch 13 in Laoag City was assigned the case, and both appellants pleaded not guilty during their arraignment.
The Prosecution's Version
- On October 8, 2011, SPO4 Rovimanuel Balolong received a tip about a drug transaction involving Abigail Cacal y Valiente.
- The following morning, a buy-bust operation was conducted, with PO1 Jackson Bannawagan Sugayen acting as the poseur buyer.
- The operation took place in front of Data Center Philippines, where Cacal facilitated the introduction of De Vera as the seller.
- De Vera handed the plastic sachet containing shabu to Cacal, who then passed it to Sugayen in exchange for the buy-bust money.
- Both appellants were apprehended shortly after the transaction, and the seized items were documented at the police station.
The Defense's Version
- Cacal claimed he was in Laoag for a job offer and had no involvement in any drug transaction, asserting that he was framed by the police.
- De Vera testified that she was merely collecting a debt from