Case Summary (G.R. No. 225634)
Charges and Proceedings
The accused-appellants were charged with multiple counts of violations of Republic Act No. 9165, also known as the "Comprehensive Dangerous Drugs Act of 2002," under Sections 5 and 11, which pertain to illegal delivery and illegal possession of dangerous drugs. Following their arrest during a police buy-bust operation, they were arraigned on September 26, 2008, but opted not to enter pleas, leading the court to enter a plea of not guilty on their behalf.
Summary of Allegations
On the day of the alleged offenses, a police team conducted a planned buy-bust operation after receiving information regarding Jao's involvement in drug sales. After successfully executing the operation, Jao was apprehended and found in possession of several plastic sachets of methamphetamine hydrochloride (shabu). Subsequently, he implicated Catigtig as his source of drugs, leading to Catigtig's arrest during a further operation that resulted in the seizure of additional sachets.
The RTC Ruling
The Regional Trial Court (RTC) of Dumaguete City rendered a joint judgment on August 25, 2011, finding both accused-appellants guilty beyond a reasonable doubt. The court concluded that the prosecution had sufficiently demonstrated the legitimacy of the buy-bust operation and that the chain of custody regarding the seized evidence was properly maintained. As a result, both Jao and Catigtig received life sentences for the illegal delivery charge and lengthy imprisonment terms for the illegal possession charge, along with substantial fines.
CA Proceedings
The accused-appellants subsequently appealed their convictions to the Court of Appeals (CA), which affirmed the RTC's decision on October 28, 2015. The CA upheld that the prosecution established all elements of the crimes charged, confirming the validity of the arrests and the integrity of the chain of custody of the evidence.
Death of the Accused
While the appeal was pending, it was reported that Catigtig had died on August 7, 2015. This caused the CA to issue a resolution referring the matter of Catigtig's death to the Supreme Court. The implications of a defendant's death on criminal liability were considered under Article 89 of the Revised Penal Code, which clearly states that the death of a convict extinguishes criminal liability.
Supreme Court's Res
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Case Background
- The case involves an ordinary appeal by accused-appellants Allan Jao y Calonia (Jao) and Rogelio Catigtig y Cobio (Catigtig) regarding their convictions for Illegal Delivery and Illegal Possession of Dangerous Drugs under Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- The appeal challenges the Decision of the Court of Appeals (CA) dated October 28, 2015, which affirmed the Joint Judgment of the Regional Trial Court (RTC) dated August 25, 2011.
- The RTC convicted both accused-appellants of the aforementioned crimes based on four separate Amended Informations dated September 23, 2008.
Summary of Charges
- Criminal Case No. 19189: Jao was accused of delivering one plastic sachet containing methamphetamine hydrochloride (shabu) weighing 0.01 gram to an informant on June 2, 2008.
- Criminal Case No. 19190: Jao was also charged with possession of six plastic sachets containing shabu weighing 0.06 gram, confiscated during a search incidental to his arrest.
- Criminal Case No. 19187: Catigtig was accused of delivering ten plastic sachets of shabu weighing 0.10 gram to a law enforcer the same evening.
- Criminal Case No. 19188: Catigtig faced charges for possession of one plastic sachet containing shabu weighing 0.06 gram along with additional paraphernalia, also seized during a search.
Facts of the Case
- A police team, acting on information regarding Jao's involvement in drug sales, conducted a buy-bust operation on June 2, 2008.
- The operation involved Jao delivering shabu to