Case Summary (G.R. No. 171732)
Procedural History
The RTC of Malabon City initially convicted Acurda and sentenced him to life imprisonment along with a fine of P500,000. The case stemmed from two informations: the first charged illegal possession of shabu, and the second charged illegal sale. Acurda pleaded not guilty to both charges. The RTC found him guilty of drug pushing but acquitted him of illegal possession. This decision was subsequently affirmed by the CA.
Factual Background
The prosecution's case relied on the testimonies of two police witnesses: P/A Ronald Ticlao and PO1 Alexander Carlos. P/A Ticlao testified about Acurda's arrest in connection with illegal drugs on July 30, 2002, while PO1 Carlos recounted a buy-bust operation on February 17, 2003, during which Acurda allegedly sold shabu. Both witnesses expressed confidence in identifying the accused and the substances involved in the operations. Acurda's defense argued that he was a victim of a set-up and extortion by the police.
Judicial Findings
At the RTC, Acurda was found guilty based on the testimonies of the police officers, which the court deemed credible, despite Acurda's claims of frame-up. The evidentiary basis included the seized drugs and associated documents. However, during the appeal, Acurda contended the prosecution had not established a proper chain of custody for the evidence.
Legal Requirements for Conviction
The Supreme Court emphasized that a valid conviction under RA No. 9165 requires a strict adherence to procedural guidelines, particularly concerning the presentation and handling of seized drugs. The court quoted relevant legal provisions, highlighting the need for procedural compliance to establish the integrity and identity of the corpus delicti.
Chain of Custody Issues
The Supreme Court found significant deficiencies in the prosecution's handling of evidence. The buy-bust team failed to conduct a physical inventory or photographs in the presence of required witnesses, which are necessary for preserving the identity and integrity of the seized items. Moreover, there was a lack of clarity regarding the marking of evidence, the transfer of custody, and the individuals involved throughout the
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Case Overview
- The case involves the conviction of Edgar Denoman y Acurda (accused-appellant) for the illegal sale of shabu under Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
- The Regional Trial Court (RTC), Branch 72, Malabon City, initially rendered a judgment of conviction, which was affirmed by the Court of Appeals (CA) on January 16, 2006.
Charges Against the Accused
- The accused was charged with two different criminal cases:
- Criminal Case No. 27283-MN: Illegal possession of dangerous drugs (shabu) on July 30, 2002.
- Allegations: Possession of one heat-sealed transparent plastic sachet containing 0.04 grams of shabu.
- Criminal Case No. 28387-MN: Illegal sale of shabu on February 17, 2003.
- Allegations: Sale and delivery of one heat-sealed transparent plastic sachet containing 0.03 grams of shabu for P100.00.
- Criminal Case No. 27283-MN: Illegal possession of dangerous drugs (shabu) on July 30, 2002.
Prosecution's Case
- The prosecution presented two key witnesses:
- P/A Ronald Ticlao: Informed about illegal drug activities and identified the accused during a narcotics operation.
- PO1 Alexander Carlos: Acted as a poseur buyer during a buy-bust operation, positively identifying the accused as the seller of shabu.
- Evidence presented included:
- Testimonies detailing the operations and the seizure of shabu.
- Documentary evidence such as laboratory reports, physical evidence of shabu, and affidavits of arrest.