Case Summary (G.R. No. 238212)
Applicable Law
The pertinent legislation in this case is Republic Act No. 9165, specifically Section 5, Article II, concerning the Illegal Sale of Dangerous Drugs, and Section 11 of the same law, which pertains to Illegal Possession of Dangerous Drugs.
Summary of the Facts
The charges arose from two separate Informations filed against the accused-appellants at the Regional Trial Court (RTC) in Balanga City, Bataan. On October 6, 2015, an illegal drug operation was conducted by the Balanga City Police, targeting Gil Obordo, who identified Dela Cruz as his supplier. Following this identification, a buy-bust operation was executed, wherein Dela Cruz was caught selling a plastic sachet containing shabu to a poseur-buyer, Police Officer 1 Michael Disono. Concurrently, Forbes was found in possession of another sachet after receiving it from Dela Cruz. The drugs were subsequently examined and yielded positive results for methamphetamine hydrochloride.
Proceedings in the RTC
During the RTC trial, the prosecution presented evidence establishing Dela Cruz's illegal sale of drugs and Forbes's possession. The RTC found both accused guilty and sentenced Dela Cruz to life imprisonment and a fine of P500,000; Forbes received a sentence of 12 years and 1 day to 15 years imprisonment, along with a fine of P300,000. The court dismissed their claims of a frame-up as unsubstantiated.
Appeal to the Court of Appeals
The accused-appellants appealed the RTC’s ruling to the Court of Appeals (CA). In its Decision dated November 27, 2017, the CA affirmed the RTC’s findings and conclusions, stating that the prosecution successfully proved all elements of the crimes charged against the appellants and maintained that the chain of custody over the evidence was intact.
Court's Ruling on Appeal
The Supreme Court determined that the appeal was without merit. It reiterated the elements necessary to constitute the offenses of Illegal Sale and Illegal Possession of Dangerous Drugs under RA 9165. The Court upheld that both Dela Cruz and Forbes's actions during the drug transaction were adequately documented and consistent with the law's requirements, particularly regarding the chain of custody. The court confirmed that the marking, inventory, and photography of the seized drugs conformed to requirements, thus preserving the evidentiary integrity necessary for a successful prosecution.
Conclusion and Final Ruling
The appeal was dismissed, and the CA's Decision was affirmed. Consequent
Case Syllabus (G.R. No. 238212)
Case Overview
- The case involves an ordinary appeal against the Decision of the Court of Appeals dated November 27, 2017.
- The appeal concerns the Joint Decision dated August 4, 2016 of the Regional Trial Court (RTC) of Balanga City, Bataan.
- Accused-appellant Christian Dela Cruz y Dayo was found guilty of Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165.
- Accused-appellant Arsenio Forbes y Dayo was found guilty of Illegal Possession of Dangerous Drugs under Section 11 of the same law.
Factual Background
- The case originated from two Informations filed against Dela Cruz and Forbes for illegal drug-related offenses.
- On October 6, 2015, police conducted a successful operation against a certain Gil Obordo, during which Dela Cruz was identified as his drug supplier.
- A buy-bust operation was set up, with Police Officer 1 Michael Disono acting as the poseur-buyer.
- Dela Cruz arrived at the meeting place on a motorcycle driven by Forbes and handed a sachet containing methamphetamine hydrochloride (shabu) to Forbes before approaching PO1 Disono to complete the sale.
- Both accused were arrested, and illegal items were recovered from them, with subsequent inventory and examination confirming the substances as shabu.
Defense Narratives
- Dela Cruz claimed he was flagged down by men in c