Case Summary (G.R. No. 233033)
Procedural History
Guanzon was charged in two separate Informations for illegal sale and possession of dangerous drugs on July 28, 2003. After pleading not guilty during his arraignment, the case proceeded to trial. The Regional Trial Court (RTC) initially found him guilty on February 18, 2016, imposing a life sentence for illegal sale and a lengthy imprisonment for illegal possession, which prompted Guanzon to appeal to the Court of Appeals (CA).
Prosecution's Version of Events
On July 28, 2003, the Philippine National Police (PNP) received tips regarding Guanzon's alleged drug activity. A buy-bust operation was organized, where a police officer posed as a buyer, and Guanzon allegedly sold him a sachet of methamphetamine (shabu) in exchange for ₱200. Following this, a search yielded another sachet in Guanzon's possession, both leading to his arrests. The sachets were subsequently identified as shabu through lab tests.
Defense's Version of Events
The Defense claimed that Guanzon was wrongfully arrested when armed men entered a dwelling during a separate incident and identified themselves as police officers. Guanzon's argument centered on a lack of harmful evidence at the time of his arrest and alleged a fabrication of the buy-bust story by the officers, claiming they had no legal basis to charge him.
RTC Decision
Analyzing the evidence presented, the RTC ruled against Guanzon, determining that he was guilty beyond a reasonable doubt and sentenced him accordingly. Guanzon appealed this decision, focusing on procedural violations regarding the handling of evidence.
Court of Appeals Ruling
The CA upheld the RTC's decision, ruling that the prosecution's evidence, both testimonial and documentary, demonstrated an unbroken chain of custody. The CA dismissed Guanzon's claims regarding the police's failure to follow mandatory procedures in documenting the buy-bust operation, citing minor discrepancies in testimony that did not undermine the overall credibility of the evidence.
Supreme Court Ruling
Upon review, the Supreme Court found merit in Guanzon's appeal, emphasizing that strict compliance with the provisions of Section 21 of R.A. No. 9165 is necessary to ensure the integrity of evidence in drug-related cases. The Court highlighted the prosecution's failure to establish an unbroken chain of custody, noting inconsistencies in the testimonies provided by law enforcement witnesses regarding the handling of the evidence, which raised doubts about the identity and integrity of the seized drugs.
Key Points on Chain of Custody
The Court reiterated that for convictions in drug-r
...continue readingCase Syllabus (G.R. No. 233033)
Case Overview
- The case involves an appeal by Ricardo Guanzon y Ceneta against his conviction for violating Sections 5 (illegal sale) and 11 (illegal possession) of Article II of R.A. No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002.
- The decision from the Regional Trial Court (RTC) in Antipolo City, which found Guanzon guilty beyond reasonable doubt, was affirmed by the Court of Appeals (CA).
- The Supreme Court emphasized the necessity for strict adherence to the chain of custody of evidence in drug-related offenses, particularly the requirements set forth in Section 21 of R.A. No. 9165.
Facts of the Case
- Guanzon was accused of selling and possessing dangerous drugs on July 28, 2003, in Antipolo City.
- Criminal Case No. 03-26225: Guanzon allegedly sold 0.04 grams of shabu to PO2 Vandever D. Hernandez for P200.00.
- Criminal Case No. 03-26226: Guanzon was found in possession of 0.01 grams of shabu.
- Guanzon pleaded not guilty during arraignment, leading to pre-trial and trial.
Prosecution's Version
- The prosecution's case was initiated by a buy-bust operation after receiving tips about Guanzon's drug dealing activities.
- The operation involved several police officers, with PO2 Hernandez acting as the poseur buyer.
- Hernandez approached Guanzon, exchanged marked money for a plastic sachet of shabu, and signaled the team to arrest Guanzon.
- Upon arrest, police recovered marked money and another sachet of shabu from Guanzon.
- The sachets were marked, inventoried, and sub