Case Summary (G.R. No. 216754)
Procedural History
Havib was charged with violating Section 5, Article II of RA 9165. Following his not guilty plea, the Regional Trial Court (RTC) initially convicted him of illegal possession of dangerous drugs instead of illegal sale. Havib sought relief from the Court of Appeals (CA), which affirmed the conviction for illegal sale and imposed a life sentence.
Facts and Evidence Presented
The prosecution's case, led by PDEA agents, detailed an operation where a poseur buyer, Roderick P. Falle, was involved. Falle was given marked money to purchase shabu from Havib, who was allegedly observed selling two sachets of the drug. Following the transaction, Havib was apprehended, and the seized items were submitted to the PNP Regional Crime Laboratory, confirming the substance as shabu.
Defense's Position
In contrast, the defense argued that Havib was merely in Tacurong City for personal errands and was wrongfully arrested. It contended that there was no legitimate sale or possession of illegal drugs, presenting Havib’s alibi and asserting the implausibility of the prosecution’s narrative.
RTC’s Ruling
The RTC found the evidence insufficient to support the charge of illegal sale but convicted Havib of illegal possession. The main reasons included the absence of the confidential informant during the trial and the contention that the alleged poseur buyer acted more like a delivery person than a buyer. The RTC sentenced Havib to a significant prison term and a monetary fine.
CA’s Ruling
The CA reversed the RTC's findings, asserting that all elements of illegal sale were met, largely discrediting the defense’s arguments. The CA emphasized the credibility of the poseur buyer’s testimony and considered minor inconsistencies in the testimonies as not affecting overall reliability. Consequently, it sentenced Havib to life imprisonment.
Supreme Court's Ruling
Upon review, the Supreme Court concluded that the prosecution failed to establish a chain of custody for the confiscated drugs, crucial for the integrity of the evidence. It highlighted that Section 21 of RA 9165 mandates strict compliance with the procedures concerning
...continue readingCase Syllabus (G.R. No. 216754)
Case Background
- Court: Supreme Court of the Philippines
- Division: Second Division
- Case Number: G.R. No. 216754
- Date of Decision: July 17, 2019
- Respondents: People of the Philippines, Plaintiff-Appellee
- Appellant: Havib Galuken y Saavedra, Accused-Appellant
Procedural History
- The case is an appeal under Section 13(c), Rule 124 of the Rules of Court from the Decision dated November 5, 2014, by the Court of Appeals (CA) in CA-G.R. CR No. 00972-MIN.
- The CA affirmed the Judgment dated June 22, 2010, rendered by the Regional Trial Court (RTC), Branch 20, Tacurong City, which found the accused guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, as amended.
Facts of the Case
- Charge: Havib was charged with violating Section 5, Article II of RA 9165.
- The Information stated that on May 26, 2009, at approximately 5:35 PM, Havib sold to Roderick P. Falle two sachets of Methamphetamine Hydrochloride, commonly known as Shabu.
- Upon arraignment, Havib pleaded not guilty.
Version of the Prosecution
- The prosecution's narrative, adopted by the CA, involved detailed preparations for a narcotics operation led by the Philippine Drug Enforcement Agency (PDEA).
- The operation included a briefing where Roderick P. Falle was designated as the poseur buyer and given marked money.
- The transaction occurred at Caltex Station, where Havib was approached and sold two sachets of shabu to Falle.
- Following the sale, Havib attempted to flee but was ap