Case Summary (G.R. No. 260990)
Applicable Law
- Republic Act No. 9165: Known as the Comprehensive Dangerous Drugs Act of 2002, particularly Sections 5 (Illegal Sale) and 11 (Illegal Possession) of Article II.
Facts of the Case
The case originated from two Informations alleging that accused-appellant Anthony David y Matawaran illegally sold and possessed dangerous drugs (Methamphetamine Hydrochloride or "shabu") on August 16, 2015, in Samal, Bataan. The prosecution indicated that during a buy-bust operation, Matawaran sold one sachet of shabu and was subsequently found in possession of another sachet following his arrest.
Prosecution's Version
The operation was initiated upon receiving information about Matawaran's illegal drug activities. Police Officer 1 Joey Santos was appointed as the poseur-buyer, and a buy-bust team was organized. During the operation, Matawaran allegedly sold a sachet of shabu and was caught with another sachet in his possession following his arrest. The police officers conducted a physical inventory and subsequently brought the seized items for chemical analysis, which confirmed the presence of shabu.
Defense's Argument
Matawaran denied the allegations, claiming the police arrested him without cause and stated that he was shown drugs only after being taken to the police station. He insisted that the drugs were not recovered from his possession. His father testified on his behalf, stating he was initially prevented from speaking to his son upon arrival at the police station.
Ruling of the Regional Trial Court
The trial court held that the prosecution successfully proved the charges beyond reasonable doubt, maintaining that the integrity of the items as evidence was preserved. It emphasized the credibility of the law enforcement officers involved, ruling that the elements of illegal sale and possession were sufficiently established.
Ruling of the Court of Appeals
The Court of Appeals affirmed the trial court's decision, stating that the prosecution discharged its burden of proof, and that the penalties imposed were consistent with the law under RA 9165.
Key Legal Issue
The essential issue for determination was whether the prosecution convincingly proved the accused's guilt beyond reasonable doubt concerning the charges of illegal sale and possession of dangerous drugs.
Court's Ruling
The Supreme Court ruled in favor of the accused-appellant, granting the appeal. The Court underscored the importance of adhering to the chain of custody rules as mandated by Section 21 of RA 9165. Notably, it expressed concerns about the inventory and photography of the seized items being conducted at the police station rather than at the site of the seizure. The police did not provide adequate justifications for this procedural deviation, leading to a fatal compromise of integrity regar
...continue readingCase Syllabus (G.R. No. 260990)
Background and Parties Involved
- The case involves the People of the Philippines as the plaintiff-appellee and Anthony David Y. Matawaran @ "Anto" as the accused-appellant.
- The case proceeds from two separate criminal complaints filed against Matawaran for violations of the Comprehensive Dangerous Drugs Act of 2002 (RA 9165), specifically:
- Criminal Case No. 15095 for Illegal Sale of Dangerous Drugs under Section 5, Article II.
- Criminal Case No. 15096 for Illegal Possession of Dangerous Drugs under Section 11, Article II.
- Both offenses allegedly occurred on August 16, 2015, in Samal, Bataan, Philippines.
- The accused pleaded not guilty to the charges.
Facts and Incident Description
- A confidential informant reported to local police about Matawaran's involvement in illegal drug sale.
- Police officers, coordinated by their Chief, organized a buy-bust operation involving PO1 Joey Santos (poseur-buyer) and SPO1 Rommel Buduan (backup).
- PO1 Santos was provided with P500 marked money to purchase suspected "shabu" (methamphetamine hydrochloride) from Matawaran.
- At the operation site, the transaction occurred with Matawaran handing a heat-sealed sachet suspected to contain "shabu".
- After the buy-bust, Matawaran was arrested and frisked, resulting in the recovery of a second sachet.
- Both sachets were marked post-operationally as "JCS-1" and "JCS-2."
- Physical inventory and photographs of the seized items were taken at the police station with witnesses from the DOJ, media, and an elected barangay official.
- Laboratory examination confirmed the presence of methamphetamine hydrochloride.
Prosecution’s Version
- The prosecution presented the detailed sequence of the buy-bust operation and arrest.
- Police narration included receiving the information from the confidential informant, briefing of the buy-bust team, marking, inventory, and chain of custody.
- Both seized specimens tested positive for methamphetamine hydrochloride.
- Backup officer SPO1 Buduan corroborated the conduct of the buy-bust and arrest but admitted he was not shown the contents of the pockets before items were placed.
Defense Version
- Matawaran denied the allegations, asserting he was merely stopped and arrested while driving his tricycle.
- He denied selling or possessing illegal drugs and contested the seizure.
- He testified that the police immediately handcuffed and frisked him without explanation initially, only later showing alleged seized items at the police station.
- His father corroborated the arrest circumstances and testified on the familiarity with the police officers.
Court of First Instance (RTC) Decision
- The RTC found the accused guilty beyond reasonable doubt for both charges.
- It credited the testimony of the police officers, highlighting their presumption of regularity in performing duty.
- Noted that illegal drugs were recovered during a lawful arrest and marked accordingly.
- Imposed penalties:
- Life impr