Case Summary (G.R. No. 250908)
Applicable Law
This case pertains to the provisions of Republic Act No. 9165, known as the "Comprehensive Dangerous Drugs Act of 2002." Specifically, the accused was charged with violating Section 5, in relation to Section 26, which addresses the illegal sale of dangerous drugs and the penalties for such offenses.
Factual Background
The complaint arose from an incident on June 14, 2015, involving Joaquin Caparas, who was found by Jail Officer Romana to be in possession of a small sachet containing methamphetamine hydrochloride, known as shabu. Caparas testified that the narcotics were provided to him by Quiaones and that he was instructed to deliver them to another inmate, Frederick Cua. The items were confiscated, inventoried, and tested positive for illegal substances.
RTC Ruling
The Regional Trial Court (RTC) convicted Quiaones on September 4, 2017, for the attempted illegal sale of dangerous drugs and sentenced him to life imprisonment and a fine of ₱500,000. The RTC accepted the testimony of Caparas as credible and direct evidence linking Quiaones to the crime, despite the fact that Quiaones was not found in possession of the drugs at the time of the incident.
CA Ruling
On November 29, 2018, the Court of Appeals (CA) affirmed the RTC’s decision. The CA ruled that Quiaones' denial could not outweigh the testimony of the prosecution witnesses, in addition to finding that the prosecution had sufficiently established the elements of the crime and preserved the integrity of the chain of custody of the seized items.
Core Issue
The primary issue for resolution by the Court was whether Quiaones was guilty beyond a reasonable doubt of the charge of attempted illegal sale of dangerous drugs.
Court's Ruling
The Court granted the appeal and acquitted Quiaones, determining that reasonable doubt existed regarding his guilt. The Court highlighted that the prosecution's case relied significantly on Caparas's testimony, which lacked corroborative evidence from other sources. It noted that Caparas, who was in possession of the illegal drugs, had an incentive to shift blame to Quiaones to evade his own criminal liability.
Evidence Evaluation
The Court critically examined the evidence and concluded that the prosecution failed to establish the identities of the buyer and seller of the drugs with moral certainty. The testimony of Jail Officer Romana and Warden Pajarillo did not support Caparas's claims linking Quiaones to the selling of the drugs, undermining the credibility of the prosecution's case. The note found with Caparas did not specifically mention Quiaones as the supplier or Cua as the intended buyer, further complicating the prosecution
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Case Background
- The case involves an appeal by accused-appellant Ariel QuiAones y Loveria challenging the Decision dated November 29, 2018, of the Court of Appeals (CA) which upheld the Regional Trial Court's (RTC) conviction of the appellant for Attempted Illegal Sale of Dangerous Drugs.
- The offense pertains to the sale of methamphetamine hydrochloride, commonly known as shabu, as defined under Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
Facts of the Case
- Incident Overview: On June 14, 2015, at approximately 3:40 PM, while conducting a roll call at the Camarines Norte Provincial Jail, Jail Officer Niel A. Romana (JO Romana) confronted Rogelio B. Caparas, a minor trustee-inmate, who was found carrying a note sealed with electrical tape.
- Seizure of Evidence: Upon searching Caparas, JO Romana discovered a handwritten note, a small plastic sachet containing 0.0944 grams of a white crystalline substance, and rolled aluminum foil. These items were confiscated and later tested positive for shabu.
- Testimonies: JO Romana reported the incident, and the seized items were inventoried in the presence of other officials, including Philippine Drug Enforcement Agency Agent Enrico Barba. Caparas testified that the note and sachet were given to him by accused-appellant to deliver to another inmate, Frederick Cua.
- Accused-Appellant's Defense: Ariel QuiAones y Loveria denied the charges, claiming he was in his cell at the time of the incident and only became aware of the ac