Case Summary (G.R. No. 234151)
Applicable Law
The applicable law is Section 5, Article II of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, which penalizes the illegal sale and distribution of dangerous drugs.
Facts of the Case
The Information against Dela Cruz charged that on June 6, 2010, he unlawfully sold shabu weighing approximately 0.02 grams to a poseur buyer, who was an agent of the Philippine Drug Enforcement Agency (PDEA). The designated buy-bust money used in the operation consisted of two P500 bills, marked with specific serial numbers. Dela Cruz was apprehended during the transaction, wherein he was caught attempting to sell the illegal substance.
Version of the Prosecution
The prosecution detailed a well-coordinated buy-bust operation initiated upon receiving a tip-off regarding Dela Cruz’s illegal activities. After a briefing with the designated poseur buyer, Dela Cruz was located and approached at his residence, where the transaction occurred. The prosecution presented evidence that included the confiscated sachet containing shabu, which was submitted to the PNP Regional Crime Laboratory for analysis, returning a positive result for methamphetamine.
Version of the Defense
In defense, Dela Cruz and his son testified that the accused was innocent and claimed that five PDEA agents unlawfully entered their home, pointing a firearm at Dela Cruz and arresting him without any legal basis. Dela Cruz alleged that he was tortured by the PDEA operatives to divulge information on other drug personalities.
Ruling of the RTC
The Regional Trial Court (RTC) found Dela Cruz guilty as charged, noting that the prosecution established beyond reasonable doubt the two required elements of illegal sale of drugs. The defense's claims of irregularities and torture were dismissed as self-serving and unsupported by corroborating evidence. Consequently, the RTC imposed life imprisonment and a fine of PHP 500,000, along with the confiscation of the illegal drugs for proper disposition.
Ruling of the CA
The Court of Appeals (CA) affirmed the RTC's decision, opining that the prosecution successfully proved all the elements of illegal drug sale, and dismissed the defense’s claims regarding procedural lapses in the execution of the buy-bust operation, ruling that non-compliance with certain procedures did not invalidate the seizures.
Issue on Appeal
The pivotal issue on appeal was whether Dela Cruz's guilt for violation of Section 5 of RA 9165 was proven beyond reasonable doubt.
Supreme Court's Ruling
The Supreme Court found merit in the appeal and acquitted Dela Cruz. The Court emphasized that in drug-related cases, the identity and integrity of the seized drugs are crucial for a conviction. It pointed out the necessity of establishing an unbroken chain of custody for the evidence, which includes conducting physical inventories and securing the presence of designated witnesses immediately after seizure at the point of arrest.
Non-Compliance with Chain of Custody Requirements
It was determined that the buy-bust team failed to follow the mandatory requirements under Section 21 of RA 9165, particularly regarding the immediate marking and photographing of the evidence at the place of arrest. Additionally,
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Case Background
- Case Citation: 844 Phil. 1012
- Date of Decision: December 5, 2018
- Court: Supreme Court of the Philippines, Second Division
- Parties Involved:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Cesar Dela Cruz y Libonao, also known as "Sesi"
Procedural History
- The case is an appeal under Section 13(c), Rule 124 of the Rules of Court.
- The appeal arises from the Court of Appeals’ Decision dated September 6, 2016, which affirmed the Regional Trial Court’s (RTC) ruling dated September 2, 2013.
- The RTC found Dela Cruz guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
Facts of the Case
- Incident Date: June 6, 2010
- Location: Municipality of Aparri, Province of Cagayan
- Charges Against Dela Cruz:
- Selling, delivering, dispensing, and distributing one piece of heat-sealed transparent plastic sachet containing methamphetamine hydrochloride (shabu), weighing approximately 0.02 grams, for a price of PHP 1,000.00.
- Arrest Circumstances:
- Dela Cruz was apprehended during a buy-bust operation led by the Philippine Drug Enforcement Agency (PDEA).
- The operation was initiated after a tip-off from a confidential informant about Dela Cruz's illegal drug activities.
Prosecution's Version
- Initiation of Operation:
- A confidential informant alerted the PDEA, leading to a buy-bust operation plan.
- IO2 Vivien A. Molina was designated as the poseur buyer.
- Execution of Buy-Bust:
- At approximately 8:30 PM, the poseur buyer and the informant approached Dela Cruz at his residence.
- Dela Cruz handed over the sachet of shabu to Molina in exchange for PHP 1,000.00.
- Upon the transaction's completion, Molina ign