Case Summary (G.R. No. 235658)
Background of the Case
The case arises from two Informations filed against Raul Del Rosario y Niebres in the Regional Trial Court (RTC) for violations of Sections 5 and 11, Article II of R.A. No. 9165. The accusations pertain to the illegal sale and possession of dangerous drugs, specifically Methamphetamine Hydrochloride or "shabu," occurring on April 21, 2008. Appellant pled not guilty during the arraignment, initiating the trial process.
Prosecution's Version of Events
The prosecution established its case through the testimony of the arresting officer, SPO1 Naredo, who led a buy-bust operation following a tip from a confidential informant indicating that appellant was engaged in illegal drug activities. During the operation, the informant purchased drugs from Niebres, and upon the arrest, additional drugs were recovered from him. The drugs exhibited positive results for "shabu" following forensic examination, supporting the charge against him.
Defense's Version and Arguments
The defense contested the prosecution's account, asserting a frame-up. Appellant claimed that he was forcibly taken to a location by unidentified men and later presented with drugs by police. A neighbor corroborated appellant's claim by testifying about the noises and events leading up to appellant's arrest.
RTC Ruling
On July 22, 2015, the RTC convicted appellant, imposing life imprisonment for the sale of dangerous drugs and a separate penalty for possession. The RTC upheld the integrity of the evidence based on the presumption of regularity in police operations, giving no credence to the defense's arguments of denial or frame-up.
CA Ruling
The Court of Appeals affirmed the RTC's decision on February 22, 2017, agreeing that the prosecution proved the offense elements were sufficiently established, although it acknowledged procedural lapses regarding the inventory and photography of the seized drugs.
Legal Issue on Appeal
The primary issue for this appeal is whether the prosecution proved beyond a reasonable doubt the guilt of the appellant, specifically regarding adherence to the chain of custody regulations mandated by R.A. No. 9165.
Chain of Custody and Procedural Compliance
The Supreme Court emphasized the necessity of strict adherence to the procedures outlined in Sec. 21 of R.A. No. 9165 concerning the inventory and photography of seized drugs. The case revealed significant lapses: the arresting officers failed to properly inventory, photograph the items, or secure the presence of required witnesses. These failures undermined the chain of custody, which is crucial in drug-related offenses to ensure that the evidence remains integral and unaltered.
Supreme Court's Findings
The Court determined that the prosecution did not sufficiently establish the continuity of the chain of custod
...continue readingCase Syllabus (G.R. No. 235658)
Case Background
- This case involves an appeal from the February 22, 2017 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 07680.
- The CA upheld the July 22, 2015 Judgment of the Regional Trial Court (RTC) of Calamba City, Branch 37, which convicted Raul Del Rosario y Niebres (appellant) of illegal sale and possession of dangerous drugs under Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
Charges Faced by the Appellant
- The appellant was charged with:
- Criminal Case No. 15745-2008-C: Illegal Sale of Dangerous Drugs (Sec. 5, Article II of R.A. No. 9165) for selling one plastic sachet containing Methamphetamine Hydrochloride ("shabu") weighing 0.01 gram.
- Criminal Case No. 15746-2008-C: Illegal Possession of Dangerous Drugs (Sec. 11, Article II of R.A. No. 9165) for possessing a quantity of Methamphetamine Hydrochloride weighing 0.09 grams.
Procedural History
- The appellant pleaded "not guilty" during his arraignment on May 14, 2008.
- The prosecution presented witnesses, including Forensic Chemist Lalaine Ong Rodrigo and Senior Police Officer I Apolonio Naredo, to establish the charges against the appellant.
Prosecution's Version of Events
- A confidential informant notified SPO1 Naredo about the appellant's illegal drug activities.
- A buy-bust operation was initiated, and the team proceeded to a billiard hall in Brgy. Pansol where the informant