Case Summary (G.R. No. 205764)
Key Dates
The decision by the Supreme Court was rendered on February 3, 2016, following the Court of Appeals' ruling dated February 28, 2012.
Applicable Law
This case pertains to violations of the Comprehensive Dangerous Drugs Act of 2002, specifically Section 5, Article II of Republic Act No. 9165.
Overview of the Case
The case originated from an Information filed on August 16, 2005, charging the accused with the illegal sale of 2,722 grams of marijuana. The prosecution conducted a buy-bust operation on August 14, 2005, during which undercover officers purchased marijuana from Enad, resulting in his arrest.
Prosecution's Evidence
The prosecution brought three witnesses to testify: Police Inspector Leoncio G. Demauro, Police Inspector Arceliano A. BaAares, and Jude Daniel Mendoza, a forensic officer. They outlined the circumstances leading to the buy-bust operation, claiming that the transaction was executed successfully and that the marijuana was marked and prepared for examination as required by law. The evidence and testimony contentions supported the prosecution's claim that all elements of illegal sale were satisfied.
Defense's Assertion
Enad served as the only witness for the defense, asserting that he was unlawfully arrested and had no involvement with the marijuana. He claimed that he was accosted by police while en route to visit a relative, denied ownership of the marijuana, and was pressured to sign documents under duress. The defense argued that the chain of custody for the seized evidence was flawed, thereby questioning the integrity of the prosecution's case.
Trial Court's Findings
The Regional Trial Court found the testimony and documentary evidence presented by the prosecution credible, leading to Enad’s conviction for the illegal sale of drugs. The court highlighted the execution of the buy-bust, the identity of the seller and buyer, and the recovery of both the drugs and the buy-bust money. The court maintained that despite discrepancies regarding the timing of events, these were minor and did not negate the establishment of the crime.
Court of Appeals' Affirmation
The Court of Appeals affirmed the trial court's ruling, emphasizing that the prosecution met its burden of proof regarding all elements of the offense and that substantial compliance with procedural requirements concerning the custody and disposition of the seized drugs was achieved, discounting any defense assertions to the contrary.
Supreme Court's Ruling
Upon appeal, the Supreme Court reversed the decision of the Court of Appeals, finding that the prosecution failed to establish an unbroken chain of custody for the seized marijuana. Specifically, the Court noted deficiencies in evidence concerning how and by whom the marijuana was marked, who had custody at various points, and the lack of adherence to the legal requirements concerning the inventory and immediate marking of the evidence in the accused's presence.
Chain of Custody Failures
The Supreme Court outlined the essential elements for the chain of custody in drug-related cases, underscoring that it is crucial to establish each link for validity in cour
...continue readingCase Syllabus (G.R. No. 205764)
Overview of the Case
- The case involves an appeal by Lee Quijano Enad against the Decision dated February 28, 2012, by the Court of Appeals (CA), which affirmed the judgment of the Regional Trial Court (RTC) of Toledo City, Cebu.
- Enad was found guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act (RA) No. 9165, commonly known as the Comprehensive Dangerous Drugs Act of 2002.
- The specific charge was related to the illegal sale and delivery of marijuana, wherein Enad was accused of selling 2,722 grams of dried suspected marijuana to a poseur-buyer.
Factual Background
- An Information was filed against Enad on August 16, 2005, detailing the sale of marijuana on August 14, 2005, in Barangay Bayong, Balamban, Cebu.
- Enad was arraigned on June 30, 2006, where he pleaded not guilty.
- The prosecution presented three witnesses: Police Inspector Leoncio G. Demauro, Police Inspector Arceliano A. BaAares, and Jude Daniel Mendoza, a forensic chemist.
Prosecution's Evidence
- The prosecution's narrative began with a report about Enad's alleged illegal drug activities, prompting a surveillance operation led by P/Supt. Amado Marquez.
- On August 14, 2005, a buy-bust operation was conducted where P/Insp. BaAares acted as the poseur-buyer and P/Insp. Demauro served as the back-up officer.
- The operation was meticulously planned, and upon encountering Enad, BaAares engaged him in a conversation that led to the sale of the marijuana for P1,500.00.
- Following the successful transaction, police officers arrested Enad without resistance and conducted the necessary documentation.
Defense's Argument
- Enad was the sole witness for the defense, claiming he was unjustly arrested and t