Case Summary (G.R. No. 203961)
Charges and Initial Proceedings
Mamarinta and Batuan were charged with separate counts of selling and possessing illegal drugs, specifically methamphetamine hydrochloride, commonly known as shabu. The Regional Trial Court (RTC) of Pasig City, Branch 164, issued a judgment on November 23, 2015, finding both accused guilty beyond reasonable doubt of the charges based on the evidence presented during the trial, including testimonies from police officers involved in the buy-bust operation.
Essential Evidence and Prosecution Testimony
The prosecution's case relied heavily on the testimonies of police officers detailing the buy-bust operation. Officer Rodrigo J. Nidoy, Jr., acting as the poseur-buyer, purchased shabu from Mamarinta, while Officer Jonathan B. Bueno, acting as backup, apprehended Batuan. The evidence included five plastic sachets containing shabu, which were confiscated during the arrest. The police conducted an inventory of the seized items in the presence of local officials, but media representatives were absent.
Ruling of the RTC
In its initial ruling, the RTC sentenced both accused-appellants to life imprisonment for the sale of shabu and imposed indeterminate penalties for possession. The RTC found the testimonies of the police credible and upheld the integrity of the chain of custody concerning the seized drugs, stating that all procedures were duly followed.
Accused-Appellants' Defense
Both accused-appellants denied the charges, asserting that they were wrongfully implicated and that no drugs were found in their possession. They claimed that the police had demanded money for their release and denied the legality of their arrest. Their defenses were ultimately rejected by the RTC, which found the police testimonies more credible.
Appeal to the Court of Appeals
Following their conviction, Mamarinta and Batuan appealed to the Court of Appeals (CA). They contended that the RTC had erred in its ruling, particularly regarding the chain of custody of the seized drugs. The CA affirmed the RTC's decision, stating that while there were minor procedural lapses, the overall chain of custody was substantially complied with, and the integrity of the evidence was maintained.
Supreme Court's Ruling on Chain of Custody
Upon reviewing the case, the Supreme Court underscored the necessity of strictly adhering to the procedural requirements outlined in Section 21 of the Comprehensive Dangerous Drugs Act, especially the need for a proper chain of custody when handling confiscated drugs. The Court indicated that the prosecution had failed to provide convincing evidence that justified deviations from the mandated procedures.
Grounds for Exemption from Compliance
The Supreme Court laid out parameters for justifiable non-compliance with the chain of custody requi
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Overview of the Case
- The case involves an ordinary appeal filed by accused-appellants Andidato P. Mamarinta and Jack A. Batuan against the Decision dated July 26, 2018, of the Court of Appeals (CA).
- The CA affirmed the Judgment dated November 23, 2015, of the Regional Trial Court (RTC) of Pasig City, Branch 164.
- The RTC found both accused-appellants guilty of violating Sections 5 and 11, Article II of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
Charges and Penalties
- Criminal Case No. 20483-D: Both accused-appellants were found guilty of selling shabu, resulting in life imprisonment and a fine of ₱500,000.00.
- Criminal Case No. 20484: Mamarinta was found guilty of possession of illegal drugs, resulting in an indeterminate sentence of 12 years and 1 day to 16 years, and a fine of ₱300,000.00.
- Criminal Case No. 20485: Batuan was equally found guilty of possession, receiving the same penalty as Mamarinta.
Background of the Incident
- The accused-appellants were charged based on a buy-bust operation conducted on July 19, 2015.
- The operation was initiated after a confidential informant informed the police about illegal drug activities involving a suspect known as "Gerald" at Villa Evangelista St., Pasig City.
- The buy-bust team included PO1 Rodrigo J. Nidoy, Jr. as the poseur-buyer and PO1 Jonathan B. Bueno as backup.
Buy-Bust Operation Details
- The operation commenced around 2:20 AM on July 19, 2015.
- The informant led PO1 Nidoy, Jr. to the accused-appellants, who were identified as as