Case Summary (G.R. No. 229053)
Charges and Lower Court Decisions
On July 23, 2012, two Informations were filed before the Regional Trial Court (RTC), outlining allegations against Dela Cruz: Criminal Case No. L-9497 for possession of marijuana and Criminal Case No. L-9498 for the selling of marijuana. Dela Cruz pleaded not guilty during arraignment. In its July 20, 2015 Decision, the RTC found him guilty beyond reasonable doubt and imposed severe penalties, including a life sentence for the sale of drugs.
Evidence Presented
The prosecution's case relied on testimonies from five witnesses, including police officers involved in the buy-bust operation. The operation's details indicate that Dela Cruz was apprehended after allegedly selling two plastic sachets of marijuana to a poseur-buyer, Police Officer 1 (PO1) Denver Santillan. After the arrest, additional sachets were found in Dela Cruz's possession. Laboratory tests confirmed the confiscated items were indeed marijuana.
Defense Argument
In his defense, Dela Cruz asserted that he was not involved in any drug-related activities and claimed he was unlawfully detained by individuals posing as police officers before being brought to the police station. He maintained that he had not sold any drugs and that he was coerced into making false admissions of guilt.
Appellate Court Proceedings
The case was appealed to the Court of Appeals, which upheld the RTC's decision but modified the penalty for illegal possession. The court ruled that certain procedural requirements under the law were satisfied despite allegations of lapses.
Chain of Custody and Procedural Compliance
Central to Dela Cruz's appeal is the contention that the prosecution did not comply with the chain of custody requirements mandated by the Comprehensive Dangerous Drugs Act. According to Section 21 of Republic Act No. 9165, strict compliance is required involving immediate physical inventory and photographing of seized items in the presence of third-party witnesses. Dela Cruz’s counsel emphasized that there was neither a proper inventory nor the presence of required witnesses during the buy-bust operation.
Court’s Analysis and Findings
The Supreme Court reiterated that the prosecution bears the burden of proving guilt beyond reasonable doubt. Noncompliance with established chain of custody procedures affects the integrity and admissibility of evidence. The ruling emphasized that without strict adherence to these
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Case Background
- Jordan Casaclang Dela Cruz was charged with violating Article II, Sections 5 and 11 of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, for illegal sale and possession of dangerous drugs.
- The charges stemmed from a buy-bust operation conducted on July 10, 2012, in Lingayen, Pangasinan, where Dela Cruz was accused of selling and possessing marijuana.
- The prosecution’s case relied heavily on the testimony of police officers involved in the operation, while Dela Cruz denied the allegations, claiming coercion by unidentified individuals.
Proceedings and Trial
- Two Informations were filed against Dela Cruz on July 23, 2012, leading to his arraignment where he pleaded not guilty.
- The prosecution presented five witnesses, including the poseur-buyer, PO1 Denver Santillan, who testified about the buy-bust operation.
- During the operation, PO1 Santillan marked the bills used for the transaction and later testified to the retrieval of marijuana from Dela Cruz, as well as the preservation of the evidence.
Regional Trial Court Decision
- The Regional Trial Court (RTC) f