Case Summary (G.R. No. 220715)
Case Background and Charges
On February 18, 2011, two informations were filed against Eda. In Criminal Case No. 6604, he was charged with illegal possession of shabu, specifically alleging that on February 17, 2011, he unlawfully had in his possession four heat-sealed plastic sachets containing a total of 0.08 grams of methamphetamine. In Criminal Case No. 6605, he was charged with selling one heat-sealed plastic sachet of shabu weighing 0.02 grams. Eda entered a plea of "Not Guilty" during his arraignment, leading to a trial while he remained in detention.
Prosecution Evidence
The prosecution's case was primarily supported by the testimonies of police officers involved in the buy-bust operation. On the day in question, PO2 Roman De Chavez Bejer received information from a civilian informant alleging that Eda was selling shabu. A buy-bust team was quickly assembled, and by 5:00 PM, Eda was apprehended during the operation in Barangay Caloocan. During the interaction, PO2 Bejer witnessed Eda exchange the plastic sachet for the marked purchase money. Following the arrest, additional sachets of shabu were discovered in Eda's possession.
The police duly conducted a physical inventory of the seized items, which was witnessed by officials from the Department of Justice and the barangay. The specimens were sent for laboratory testing, which confirmed the presence of methamphetamine.
Defense Evidence
In defense, Eda denied the charges, asserting that he did not sell or use drugs. He claimed that he had been drinking with his relatives during the relevant timeframe and was wrongfully accused and assaulted by police officers. He argued that the drugs recovered were planted. However, Eda failed to provide concrete evidence to substantiate his claims or demonstrate why he was targeted by law enforcement.
RTC's Findings and Ruling
The RTC convicted Eda on September 17, 2013, concluding that the prosecution had proven, beyond a reasonable doubt, all elements necessary for the charges of illegal sale and possession of shabu. It emphasized the credibility of the law enforcement witnesses, the proper conduct of procedures during the buy-bust, and the subsequent handling of the evidence. The court determined that Eda's claims of a set-up were unpersuasive and inadequately supported by evidence, resulting in significant sentences under the law: 12 years and 4 months to 14 years and 6 months of imprisonment in Criminal Case No. 6604 and life imprisonment in Criminal Case No. 6605.
CA's Affirmation of Conviction
Eda’s appeal was dismissed by the CA on December 10, 2014, which upheld the RTC’s findings. The appellate court ruled that discrepancies in the witnesses' testimonies did not weaken the prosecution's case, noting an unbroken chain of custody regarding the seized shabu. It concluded that the essential elements for both transactions—sale and possession—had been sufficientl
...continue readingCase Syllabus (G.R. No. 220715)
Case Background
- This case involves the appeal of Ronnie Boy Eda y Casani against the December 10, 2014 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 06470.
- The CA upheld the September 17, 2013 Joint Decision of the Regional Trial Court (RTC), Branch 9, Balayan, Batangas, which found Eda guilty of illegal possession and sale of Methamphetamine Hydrochloride (shabu).
- The charges stemmed from events occurring on February 17, 2011, at Barangay Caloocan, Batangas.
Charges Against the Appellant
- Criminal Case No. 6604: Eda was charged with illegal possession of shabu, specifically four heat-sealed plastic sachets weighing a total of 0.08 grams.
- Criminal Case No. 6605: Eda was charged with the illegal sale of one heat-sealed plastic sachet containing 0.02 grams of shabu.
- Both charges were in violation of Sections 11 and 5 of the Comprehensive Dangerous Drugs Act of 2002 (R.A. No. 9165).
Proceedings and Evidence
- Eda pleaded "Not Guilty" during his arraignment, and trial proceeded while he was in detention.
- The prosecution presented key witnesses from the buy-bust team, including PO2 Roman De Chavez Bejer, PO1 Reynante Brosas Briones, and PO3 Bryan De Jesus.
Prosecution's Evidence
- On February 17, 2011, PO2 Bejer was informed by a civilian asset about Eda's drug activities, leading to the formation of a buy-bust team.
- The buy-bust operation was meticulously planned, with marked money prepared and a Pre-Operation R