Case Summary (G.R. No. 212171)
Applicable Law
The relevant legislation applicable to this case is R.A. No. 9165, particularly Section 5, Article II, which penalizes the illegal sale of dangerous drugs, stipulating severe penalties including life imprisonment and substantial fines. The proceedings are guided by procedural norms established for the handling of seized drugs to ensure the integrity and admissibility of evidence.
Case Background and Trial Court Decision
The RTC, in its decision dated November 27, 2008, found Dela Cruz guilty based on the testimonies of arresting officers who conducted a buy-bust operation. The conviction was primarily based on the evidence presented, including the physical transfer of shabu in exchange for marked money. The court rejected the accused's defenses of denial and alibi, sealing her culpability based on the precise corroborative accounts of the law enforcement personnel involved.
Appeals and Affirmation
The CA affirmed the RTC’s ruling in its entirety, endorsing the credibility of the prosecution witnesses and the lawful procedure adhered to during the operation. The appellate court underscored the handling of evidence and the proper documentation of the drug seizure process, validating the findings of the lower court.
Ruling and Analysis of Evidence
The Supreme Court dismissed the appeal, upholding the accused-appellant's guilt. The decision emphasized that all elements necessary for proving the crime of illegal sale of dangerous drugs were met, particularly noting the established identity of the buyer, seller, and the transfer of illicit drugs in exchange for consideration.
Chain of Custody and Compliance with Section 21 of R.A. No. 9165
The Court addressed the contention regarding the police officers' compliance with Section 21, which outlines the protocol for the custody and disposition of seized drugs. It concluded that the prosecution had successfully demonstrated an unbroken chain of custody over the seized items, despite the absence of certain procedural measures. The testimonies of the officers and the circumstances surrounding the apprehension were deemed sufficient to preserve the integrity of the evidence.
Conclusion on Procedural Lapses
While recognizing the importance of adhering to statutory requirements, the Supreme Court indicated that minor lapse
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Case Background
- The case involves the appeal filed by accused-appellant Mercury Dela Cruz, also known as "Deday," against the ruling of the Court of Appeals (CA).
- The initial decision was rendered by the Regional Trial Court (RTC) of Cebu City, Branch 58, on November 27, 2008, which found Dela Cruz guilty of illegal sale of shabu under Sections 5, Article II of Republic Act (R.A.) No. 9165.
- The RTC sentenced her to life imprisonment and a fine of P500,000.00 for her conviction.
- The RTC based its judgment on the testimonies of law enforcement officers involved in the buy-bust operation and dismissed the appellant's defenses of denial and alibi as self-serving.
Court of Appeals Decision
- The CA affirmed the RTC’s ruling in its entirety on September 27, 2013.
- It concurred with the RTC's assessment of the evidence, emphasizing that the arresting officers followed proper procedures in handling the seized drugs.
Supreme Court Ruling
- The Supreme Court dismissed the appeal and upheld the accused-appellant's guilt, agreeing with the findings of the lower courts.
- The Court emphasized the credibility of the police officers' testimonies and the sufficiency of evidence presented.
Elements of the Crime
- The Supreme Court highlighted the essential elements required to secure a conviction for illegal sale of dangerous drugs: