Case Summary (G.R. No. 112519)
Procedural History
On April 18, 2008, the Court of Appeals affirmed the RTC's guilty verdict against Calexto Duque Fundales, Jr. on charges of illegal sale of dangerous drugs, as set forth in Section 5, Article II of the Comprehensive Dangerous Drugs Act of 2002 (Republic Act No. 9165). The RTC originally rendered its decision on March 18, 2006, sentencing Fundales to life imprisonment and a fine of PHP 500,000. Appeals followed, leading to the current proceedings.
Charges Against the Appellant
The prosecution charged the appellant with multiple violations under Republic Act No. 9165, including:
- Criminal Case No. 03-1425: Illegal sale of 0.10 grams of Methylamphetamine Hydrochloride (shabu).
- Criminal Case No. 03-1426: Illegal possession of 0.02 grams of shabu.
- Criminal Case No. 03-1427: Illegal possession of drug paraphernalia along with several co-accused.
Events Leading to Arrest
On December 2, 2003, a buy-bust operation was conducted by the Parañaque City Police, based on a tip from a confidential informant indicating illegal drug activities by the Fundales brothers. During this operation, Police Officer 1 (PO1) Soquiñya acted as the poseur-buyer, successfully purchasing shabu from the appellant, who subsequently handed over multiple sachets containing the substance.
Conviction by the RTC
The RTC found the appellant guilty in case 03-1425, emphasizing the credibility of the police officers’ testimonies. The court dismissed the other two charges, citing insufficient evidence. The decision underscored the integrity of the drug evidence handled during the buy-bust operation.
Appeals and Arguments
On appeal, the appellant contended that the RTC had erred in convicting him due to perceived lapses in the prosecution's evidence and claims that no buy-bust operation occurred. He specifically noted the absence of the forensic chemist's testimony as detrimental to establishing his guilt, arguing that without this testimony, the corpus delicti was not sufficiently proven.
Rulings on Evidence and Procedural Issues
The Supreme Court clarified that the burden of proof in drug-related cases requires establishing the identity of the buyer, seller, and the substance sold. The Court rejected the appellant's arguments regarding the non-presentation of the forensic chemist, maintaining that the corpus delicti was established through other corroborating evidence.
Furthermore, it noted that the integrity of the drugs was preserved despite the appellant's claims of improper procedural handling by law enforcement, as no objections were raised during trial about the seizu
...continue readingCase Syllabus (G.R. No. 112519)
Background of the Case
- The appeal arises from the April 18, 2008 Decision of the Court of Appeals (CA) in CA-C.R. CR-H.C. No. 02274.
- The CA affirmed the March 18, 2006 Decision of the Regional Trial Court (RTC) of Parañaque City, Branch 259, in Criminal Case No. 03-1425.
- The RTC found appellant Calexto Duque Fundales, Jr. guilty beyond reasonable doubt of violating Section 5, Article II, Republic Act (RA) No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- The sentence imposed was life imprisonment and a fine of P500,000.00.
Factual Antecedents
- On December 8, 2003, the appellant was charged with multiple violations of RA No. 9165, including illegal sale and possession of dangerous drugs.
- The specific charges included:
- Criminal Case No. 03-1425: Illegal sale of 0.10 grams of Methylamphetamine Hydrochloride (shabu).
- Criminal Case No. 03-1426: Illegal possession of 0.02 grams of shabu.
- Criminal Case No. 03-1427: Illegal possession of drug paraphernalia.
Version of the Prosecution
- On December 2, 2003, Police Superintendent Alfredo Valdez received intelligence about illegal drug activities involving the Fundales brothers.
- A buy-bust operation was organized involving multiple police officers.
- During the operation:
- PO1 Soquiñia acted as the poseur-buyer and successfully purchased shabu from the appellant.
- The appellant handed over five plastic sachets of shabu in exchange for P500.00 marked money.
- Following the transaction, the police apprehended the appellant and others present in the