Case Summary (G.R. No. 238873)
Antecedents
In response to information received from a confidential agent, the Calamba City Police Intelligence Section conducted a buy-bust operation targeting Leo Ilagan y Garcia, suspected of selling illegal drugs. On January 14, 2017, collaborating with the Philippine Drug Enforcement Agency (PDEA), an undercover police officer, PO1 Malate, approached the accused with a pre-arranged plan. During the operation, the accused sold a plastic sachet of suspected shabu to PO1 Malate for ₱500.00, after which the police team apprehended him, conducted a search, and seized further evidence, including additional sachets of shabu found at the scene.
Charges and Trial
Accused-appellant was charged with illegal sale and possession of dangerous drugs, drafting two separate Informations against him. The Regional Trial Court (RTC) found him guilty of both charges, sentencing him to life imprisonment for the sale and a prison term of 12 years and one day to 14 years for possession, along with monetary fines. Accused-appellant denied the allegations, claiming mistaken identity and challenging the integrity of the evidence collection process.
Court of Appeals Decision
The Court of Appeals affirmed the RTC's decision, leading to the accused's appeal to the Supreme Court. Accused-appellant argued insufficient proof of the charges and raised concerns regarding the procedural irregularities in the marking and inventory of the confiscated drugs, which he claimed compromised the chain of custody of the evidence.
Ruling
The Supreme Court acquitted accused-appellant Leo Ilagan y Garcia, citing a significant break in the chain of custody of the seized drugs. The Court underscored the importance of ensuring the integrity of evidence, emphasizing that the prosecution failed to meet its burden of establishing a clear and unbroken chain leading from the apprehension of the drugs to their presentation in court. Central to this ruling was the absence of required witnesses during the inventory and marking of the seized drugs, which raised reasonable doubt about the authenticity and handling of the evidence.
Chain of Custody Analysis
The Supreme Court meticulously examined each link in the chain of custody, noting:
- First Link: The absence of representatives from the National Prosecution Service or the media during the inventory undermined the initial integrity of the evidence collection.
- Second Link: Discrepancies in documentation indicated that the seized items were not transferred to the investigating officer as required, casting doubt on the handling of the evidence.
- Third Link: Lack of clarity regarding how the seized drugs were managed post-investigation accentuated concer
Case Syllabus (G.R. No. 238873)
Case Background
- This case revolves around the appeal of Leo Ilagan y Garcia (accused-appellant) against the decision of the Court of Appeals (CA) affirming his conviction by the Regional Trial Court (RTC) for violations of the Comprehensive Dangerous Drugs Act of 2002 (RA No. 9165).
- The RTC's judgment dated August 16, 2017, found the accused guilty of Illegal Sale and Illegal Possession of Dangerous Drugs based on a buy-bust operation conducted by the Calamba City Police and the Philippine Drug Enforcement Agency (PDEA).
Antecedents of the Case
- The operation was initiated based on information from a confidential informant regarding accused-appellant's involvement in drug sales.
- A buy-bust operation was conducted on January 14, 2017, in Barangay Lawa, Calamba City, where a police poseur-buyer, PO1 Julian B. Malate III, engaged the accused in a drug transaction.
- During the transaction, the accused-appellant accepted P500.00 and provided a plastic sachet containing suspected shabu to PO1 Malate, leading to his arrest.
- A subsequent search revealed more illegal items, including additional sachets of shabu and paraphernalia.
Charges Filed
- Accused-appellant faced two charges:
- Criminal Case No. 28711-17-C: Illegal Sale of Dangerous Drugs, involving 0.05 grams of shabu.
- Criminal Case No. 28712-17-C: Illegal Possession of Dangerous Drugs, involving 0.12 grams of shabu.