Title
People vs. Laway y Canoy
Case
G.R. No. 227741
Decision Date
Mar 27, 2019
Appellant acquitted due to prosecution's failure to comply with chain of custody requirements under RA 9165, casting doubt on evidence integrity.
A

Case Summary (G.R. No. 227741)

Factual Antecedents

Willard Laway y Canoy was charged with violating Section 5, Article II of RA 9165 for allegedly selling methamphetamine hydrochloride (shabu). The prosecution's case rested on a buy-bust operation conducted on May 14, 2012, where Laway was accused of selling 0.08 grams of shabu for 600 Philippine pesos. Upon identification by a confidential informant, the police conducted a planned operation leading to his arrest. During the operation, police officers recovered three sachets of shabu from Laway, alongside another sachet and marked bills used in the transaction.

Prosecution's Version

The prosecution presented multiple witnesses, including police officers and a forensic chemist, who testified regarding the buy-bust operation. Following the arrest, a physical inventory of the seized items was conducted in the presence of media representatives and an elected public official, Kagawad Ma. Ella Villaroya Emnace. The recovered items tested positive for methamphetamine hydrochloride.

Defense's Version

The defense, represented solely by the testimony of the appellant, denied the allegations. Laway claimed he was merely waiting for transport and was wrongly accused of selling drugs. He stated that he had done nothing wrong and that no drug-related items were found on him at the time of the arrest.

Ruling of the Regional Trial Court

On May 25, 2015, the Regional Trial Court adjudged Laway guilty of illegal sale of dangerous drugs, assigning credibility to the testimonies of the prosecution's witnesses over the appellant's denial. The RTC imposed a sentence of life imprisonment and a fine, concluding that the prosecution had established the requisite elements of the crime.

Ruling of the Court of Appeals

Laway appealed to the Court of Appeals, which affirmed the RTC's ruling on August 12, 2016. The CA found that the prosecution met its burden of proof and that the alleged inconsistencies in witness testimonies were inconsequential to the overall credibility of the case.

Appeal and Legal Analysis

Upon reviewing the case, the higher court found merit in Laway's appeal, particularly regarding the preservation of the evidence. The court cited Section 21, Article II of RA 9165, which mandates that a physical inventory of seized drugs must be conducted in the presence of three wit

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