Case Summary (G.R. No. 173794)
Factual Background
On August 29, 2002, Relato was arrested during a police operation aimed at combating the illegal drug trade. The police, acting on a tip-off, executed a buy-bust operation leading to the apprehension of Relato, who was charged with selling methamphetamine hydrochloride, commonly known as shabu. The prosecution alleged that he sold two sachets of shabu weighing 0.0991 grams to a poseur buyer for P500. Following his arrest, the Regional Trial Court (RTC) in Bulan, Sorsogon, tried him for violations under Section 5 of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
Proceedings and Rulings
During the trial, the prosecution presented its case, detailing the buy-bust operation, the chain of events leading to Relato’s arrest, and the seizure of the drugs. In contrast, Relato denied the allegations, claiming he was framed and narrating an alternative account of events where he merely stopped at Barangay Aquino to adjust his motorcycle before being arrested.
On August 9, 2004, the RTC convicted Relato, sentencing him to life imprisonment and imposing a fine of P500,000. Relato appealed, challenging the alleged erroneous conclusions drawn by the RTC concerning the credibility of the prosecution's witnesses and the evidence against him.
Court of Appeals’ Decision
On May 24, 2006, the Court of Appeals affirmed Relato's conviction, asserting that the trial court had properly evaluated the testimonies and evidence presented. They emphasized the trial court's position to assess witness credibility based on their demeanor during testimony. As such, they concluded that the trial court's decision should stand.
Issues Raised
Relato contended that the appellate court failed to consider factual discrepancies and legal standards. Central to his argument was the prosecution's burden to prove his guilt beyond a reasonable doubt, which he believed was not met.
The Supreme Court’s Ruling
The Supreme Court found merit in Relato’s appeal, noting significant procedural failures related to the chain of custody for the confiscated drugs. It outlined the requirements established by Republic Act No. 9165, mandating that the apprehending team must immediately conduct an inventory and photograph the seized drugs in the presence of witnesses, including the accused and representatives from the media and the Department of Justice.
The Court detailed several lapses in the buy-bust operation, including the absence of imme
...continue readingCase Syllabus (G.R. No. 173794)
Case Background
- Parties Involved: The case involves the People of the Philippines as the plaintiff-appellee and Darwin Relato y Ajero as the accused-appellant.
- Nature of the Case: Relato was charged with violating Section 5 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002, specifically for the sale of methamphetamine hydrochloride (shabu).
- Incident Date: The alleged offense occurred on August 29, 2002, during a buy-bust operation conducted by law enforcement in Barangay Aquino, Bulan, Sorsogon.
Procedural History
- Initial Arrest: Relato was arrested during a police operation on August 29, 2002, and subsequently charged on August 30, 2002, in the Regional Trial Court (RTC) of Bulan, Sorsogon.
- Plea and Trial: Relato pleaded not guilty on November 19, 2002, leading to a trial where evidence from both prosecution and defense was presented.
Prosecution's Version
- Tip-off: The operation commenced after PO3 Sonny Evasco received information from an asset that Relato would be selling drugs that night.
- Buy-Bust Operation: A team led by SPO1 Elmer Masujer was formed, and a marked P500.00 bill was prepared as buy-bust money.
- Execution of the Operation: At approximately 11:00 PM, Relato was apprehended after selling two plastic sachets of shabu to the poseur buyer.
- Seizure of Evidence: The marked buy-bust money was recovered from Relato, along with the two sachets which were later subjected to forensic examination confirming the presence of shabu.
Accused's Defense
- Denial of Allegations: Relato claimed he was framed, asserting that he