Case Summary (G.R. No. 251741)
Charges and Initial Proceedings
The accused-appellant, Chris John Custodio y Argote, faced two separate Informations under Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002, for the illegal sale and possession of dangerous drugs. Specifically, in Criminal Case No. 2015-23224, he was charged with selling 0.04 grams of methamphetamine hydrochloride ("shabu"). In Criminal Case No. 2015-23225, he was charged with possessing 3.07 grams of the same substance. The trial commenced after the accused pleaded not guilty, and the cases were consolidated for trial in the Regional Trial Court of Dumaguete City.
Prosecution's Evidence
The prosecution presented testimonies from several police officers and witnesses involved in the buy-bust operation. On October 19, 2015, Police Officer 3 Al Lester Avila received a tip that the accused was selling drugs. Following a controlled operation, Avila purchased a sachet of shabu from the accused while other officers observed. Upon the arrest of the accused, five additional sachets containing shabu were found in his possession. The subsequent inventory was conducted at a police facility, which became a focal point of the trial regarding the legitimacy of evidence preservation.
Defense's Argument
The defense presented a contrasting narrative, with Custodio asserting he was merely purchasing food when he was stopped by the police. He denied the charges, asserting that police officers fabricated the evidence against him. The defense challenged the integrity of the chain of custody for the evidence retrieved, citing procedural violations.
Ruling of the Trial Court
On July 17, 2017, the Regional Trial Court convicted Custodio of both charges, concluding that the evidence presented by the prosecution sufficiently established his guilt beyond a reasonable doubt. The court awarded severe penalties, including life imprisonment for the sale of shabu and substantial fines.
Appellate Review
The Court of Appeals upheld the trial court's decision on August 29, 2019, noting procedural anomalies but ruling that they did not warrant overturning the conviction as the evidentiary chain remained intact despite not having insulating witnesses present during the initial inventory.
Supreme Court's Resolution on Reconsideration
Upon review of the Motion for Reconsideration filed by Custodio, the Supreme Court granted the motion and overturned the previous rulings. The court emphasized the necessity of adhering to the procedural requirements for maintaining the integrity of seized evidence. Citing the earlier case "People v. Casa," the
...continue readingCase Syllabus (G.R. No. 251741)
Background and Charges
- Accused-appellant Chris John Custodio y Argote, also known as "Bolongkoy," was charged with violations of Sections 5 and 11, Article II of Republic Act No. 9165 (RA 9165), or the Comprehensive Dangerous Drugs Act of 2002.
- Two separate informations were filed: one for illegal sale of a dangerous drug (0.04 gram of methamphetamine hydrochloride or "shabu") and the other for illegal possession of dangerous drugs (5 sachets containing 3.07 grams of shabu).
- The incidents allegedly occurred on October 19, 2015, in Dumaguete City.
Pre-Trial and Trial Proceedings
- The cases were raffled to the Regional Trial Court, Branch 30, Dumaguete City and were consolidated.
- Accused-appellant pleaded not guilty to both charges.
- The prosecution presented multiple witnesses including police officers involved in the buy-bust operation, a DOJ representative, media practitioner, barangay kagawad, and forensic chemist.
- The accused-appellant testified on his own behalf, denying the charges and presenting an alternate version of events.
Prosecution's Version of Events
- A confidential informant reported that "Bolongkoy" was selling shabu.
- PO3 Al Lester Avila was assigned as the poseur buyer, with a team set up including back-up officers.
- PO3 Avila conducted a buy-bust operation, purchasing one sachet of shabu from accused-appellant in exchange for marked bills.
- Upon arrest, a frisk yielded additional sachets and paraphernalia in accused apppellant's possession.
- Items seized were marked and inventoried at the police station with signatures from witnesses including an elected barangay official, a DOJ representative, and a media practitioner.
- The seized items were submitted for qualitative examination, testing positive for methamphetamine hydrochloride.
Defense's Version of Events
- Accused-appellant claimed he was st