Case Summary (G.R. No. 182231)
Facts of the Case
On February 5, 2003, police officers received information from a police asset regarding the appellant's intent to deliver marijuana. This led to a buy-bust operation where police observed the appellant assault drugs to the asset. The operation resulted in the appellant's arrest, during which police recovered three bricks of marijuana from his possession, along with the buy-bust money. The subsequent laboratory testing confirmed the substances were indeed marijuana.
Prosecution's Evidence
The prosecution presented several witnesses, including police officers and forensic chemists, all testifying about the chain of events from the arrest, the recovery of the drugs, and the laboratory tests. The evidence included the chemistry reports establishing the presence of marijuana. The procedures followed during the arrest and the handling of the evidence adhered to legal standards.
Defense Argument
The appellant argued that he was merely instigated to commit the crime by a former coworker, Roger Fundanera, who was alleged to be a police asset. He claimed he had no intention of selling drugs and only acted at Fundanera's insistence. Multiple testimonies were brought forth by the defense to support the narrative of instigation, yet these were inconsistent and generally did not hold substantial credibility.
Court Findings and Rulings
The Regional Trial Court (RTC) of Bauang found the appellant guilty of illegal possession but acquitted him of illegal sale, sentencing him to the penalty of death initially, which was later modified to life imprisonment upon appeal due to the prohibition of the death penalty under R.A. No. 9346. The Court of Appeals upheld the RTC's ruling, emphasizing the prosecution's success in proving the elements of illegal possession and affirming the integrity of the chain of custody.
Legal Principles Applied
The decisions were grounded in the legal principles established by the Dangerous Drugs Act, particularly regarding the necessity for the prosecution to clearly establish the corpus delicti and corroborat
...continue readingCase Syllabus (G.R. No. 182231)
Case Overview
- This case involves Eddie Gum-Oyen y Sacpa, who faced two separate informations for violations of Sections 5 and 11 of Republic Act (R.A.) No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
- At his arraignment, the accused pleaded not guilty to both charges.
Pre-Trial Conference
- During the pre-trial conference, both parties agreed on several stipulations regarding the evidence:
- The existence of Chemistry Report Nos. D-049-03 and P1-002-03.
- A request for ultraviolet fluorescent dusting addressed to the Philippine National Police (PNP) Crime Laboratory.
- The identity of the accused and the date of the alleged incident.
Trial Proceedings
- The prosecution presented four witnesses:
- Police Officer (PO3) Allan BaAana
- Police Inspector and Forensic Chemist Imelda Roderos
- Senior Police Inspector and Forensic Chemist Valeriano P. Laya II
- Senior Police Officer (SPO1) Wilfredo Montero
- The defense called the accused himself, along with two other witnesses: Marilou Panit and Balloguing Gum-Oyen.
Prosecution's Case
Incident Details:
- On February 5, 2003, PO3 BaAana and SPO1 Montero received a tip about Eddie Gum-Oyen delivering marijuana in Barangay Cabaritan, Naguilian, La Union.
- They conducted a buy-bust operation with a police asset acting as the poseur-buyer, using P1,120.00 as buy-bust money.
- The appellant arrived on a tricycle, engaged with the police asset, and handed over a square-shaped object wrapped in plastic, which was identified as marijuana.
- Upon arrest, officers found three additional bricks of marijuana in the appellant's bag.
Evidence Handling:
- The buy-bust money and marijuana were recovered and marked by the