Case Summary (G.R. No. 231007)
Proceedings Before the Trial Court
Antonio Martin was accused of selling one plastic sachet of methamphetamine hydrochloride, popularly known as "shabu," on February 17, 2010, in San Leonardo, Nueva Ecija. During the trial, after pleading not guilty, Martin contended that the evidence against him was insufficient. The prosecution's case was built on testimonies from police officers, who conducted a buy-bust operation, and forensic evidence confirming the substance's illegal nature. The trial court found Martin guilty and sentenced him to life imprisonment and fined him 500,000 pesos.
The Prosecution's Version
The police initiated a buy-bust operation following a tip from a confidential informant who allegedly had previous dealings with Martin. Under the supervision of Police Chief Inspector Francisco Mateo II, arrangements were made to send the informant to purchase drugs from Martin. During the operation, police officers observed the transaction from a distance, and after confirming the buy, apprehended Martin, collecting both the marked money and the suspected drugs.
The Defense's Version
In contrast, Martin testified that he was mistakenly apprehended while urinating outside his house and that he had no involvement in drug sales. He alleged coercion by the police to admit to crimes he did not commit while being transported to the station. A witness supported his claim, stating that there were no indications of illegal drug transactions taking place.
The Trial Court's Ruling
The Regional Trial Court concluded that the prosecution had established Martin’s guilt beyond reasonable doubt. The court cited sufficient evidence, including testimonies and the positive result from forensic testing, leading to a conviction for a serious crime with severe penalties under the law. The court denied Martin's subsequent motion for reconsideration.
Proceedings Before the Court of Appeals
On appeal, Martin challenged the trial court's findings, arguing that the prosecution failed to prove that a drug sale occurred and outlined inconsistencies in witness testimonies, particularly regarding the chain of custody of the seized drugs. The Court of Appeals, however, affirmed the trial court's decision, determining that the inconsistencies were not substantial enough to undermine the credibility of the prosecution's arguments.
The Present Petition
Martin sought further review, asserting that the Court of Appeals erred in affirming his conviction. Both parties opted not to submit additional briefs, relying instead on their previous submissions to the appellate court.
Ruling on Appeal
The Supreme Court reiterated that in drug cases, the identity of the recovered substance must be established with precision through a strict chain of custody. The prosecution failed to adequately account for each link in the chain, particularly concerning the immediate marking of the seized drug at the scene of the arrest. There were breaches identified in the procedures outlined by the law, including the absence of required witnesses during crucial phases, such as the inventory and the turnover of evidence.
Breach of the Chain of Custody
The Supreme Court noted that to preserve the integrity of a drug item, officers must immedia
...continue readingCase Syllabus (G.R. No. 231007)
The Case
- The appeal seeks to reverse the Decision dated September 23, 2016, of the Court of Appeals (CA-G.R. CR-HC No. 06912).
- The appellant, Antonio Martin y Ison, was convicted for violating Section 5, Article II of Republic Act 9165 (RA 9165) and sentenced to life imprisonment and a fine of P500,000.00.
Proceedings Before the Trial Court
- Antonio Martin was charged with illegal sale of Methamphetamine Hydrochloride ("shabu") on February 17, 2010, in San Leonardo, Nueva Ecija.
- During the arraignment, Martin pleaded not guilty, and trial commenced.
- Prosecution witnesses included members of the Philippine National Police (PNP): PO3 Alfredo Gavino, PO2 Jherome Songalia, and Forensic Chemist Jebie C. Timario. The defense presented Martin and witness Emilio Portugal.
The Prosecution's Version
- On February 17, 2010, at around 4:30 PM, PO3 Gavino received a tip-off from a confidential informant about Martin's alleged drug dealings.
- A buy-bust operation was organized, with two P100 bills dusted with ultraviolet powder handed to a poseur buyer.
- At approximately 6:00 PM, Gavino and Songalia observed Martin engaging with the informant at Lacson Colleges. After the informant signaled completion of the sale, they arrested Martin.
- During the arrest, the buy-bust money was recovered from Martin, and the informant handed over a plastic sachet containing a white crystalline substance.
- Seized items were marked in Martin's presence, and a physical inventory was conducted with media representatives and a barangay councilor as witnesses.
- The substance was confirmed as methamphetamine hydrochloride through Chemistry Report No. D-0