Case Summary (G.R. No. 234040)
Factual Background
On November 28, 2014, Augusto Maganon was charged with illegal sale and illegal possession of dangerous drugs under Sections 5 and 11, Article II of Republic Act No. 9165. The prosecution alleged that on November 23, 2014, Maganon unlawfully sold two sachets of methamphetamine hydrochloride ("shabu") to a police poseur buyer, and the following day, he was found in possession of four additional sachets of the same drug without legal authority.
Version of the Prosecution
The law enforcement's buy-bust operation was initiated after receiving intelligence regarding Maganon’s drug-dealing activities. On the day of the operation, a designated police officer, PO1 Marvin A. Santos, engaged with Maganon under the guise of purchasing drugs. Upon executing the buy-bust, police apprehended Maganon and seized both the drugs purchased and additional quantities found during the arrest. Evidence was documented in accordance with procedural requirements at the barangay hall, where the items were inventoried in the presence of local officials.
Version of the Defense
Maganon's defense asserted that he was wrongfully arrested without substantive evidence against him. He testified that law enforcement officers conducted an unlawful search of his home, discovering the alleged drugs under questionable circumstances. The defense argued that the absence of proper protocol during the inventory and retrieval process rendered the evidence inadmissible.
Ruling of the Regional Trial Court
The RTC convicted Maganon on November 25, 2015, finding him guilty of both charges, citing the prosecution's successful establishment of the chain of custody for the seized drugs. Consequently, the RTC imposed severe penalties for both the sale and possession of illegal drugs, including substantial fines and multiple years of imprisonment.
Ruling of the Court of Appeals
The CA affirmed the RTC’s ruling on May 30, 2017, concluding that despite slight deviations from the procedural requirements delineated in the law governing custody and processing of confiscated drugs, the integrity and evidentiary value of the seized items had not been compromised.
Issue on Appeal
Maganon appealed, contending that the law enforcement officials violated the mandatory procedures outlined in Section 21, Article II of RA 9165, specifically during the marking, inventory, and photographing of the confiscated evidence. He argued that these violations created reasonable doubt regarding the integrity of the evidence against him.
Our Ruling
The Supreme Court found merit in the appeal. It emphasized that the prosecution must establish the identity of the seized drugs and the chain of custody with moral certainty. The ruling highlighted the critical importance of involving necessar
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Background of the Case
- The case is an appeal from the May 30, 2017 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 08159, affirming the Regional Trial Court (RTC) of Pasig City's judgment against Augusto N. Maganon for illegal sale and illegal possession of dangerous drugs, specifically methamphetamine hydrochloride (shabu).
- The RTC found Maganon guilty under Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
Factual Antecedents
- On November 28, 2014, Maganon was charged with two separate crimes:
- Crim. Case No. 19752-D for illegal sale of shabu (0.06 grams).
- Crim. Case No. 19753-D for illegal possession of shabu (0.12 grams).
- The charges arose from a buy-bust operation conducted by the Pasig City Police on November 23, 2014, based on information from a confidential informant regarding Maganon's involvement in drug sales.
Prosecution's Version
- The police, led by PCI Renato Banas Castillo, received a tip about Maganon's drug activities.
- A buy-bust operation was executed where PO1 Marvin Santos acted as a poseur-buyer.
- Santos bought two sachets of shabu from Maganon, leading to his arrest after the pre-arranged signal was given.
- Four additional sachets were recovered from Maganon during the arrest.
- The seized items were inventoried in the presence of Barangay Captain Engr